Privacy Policy

TowerBrook (which operates through TowerBrook Capital Partners L.P. and/or TowerBrook Capital Partners (U.K.) LLP) (each a “TowerBrook Entity”, and together “we” or “TowerBrook”) treats the privacy of its clients, website users and other individuals very seriously and we take appropriate security measures to safeguard your personal information. This policy explains how TowerBrook uses any personal information (i.e., any information that relates to you and that identifies or can be used to identify you, including without limitation your name, email, address, or other digital identifiers relating to you, such as IP addresses, cookies or web server logs) that you share with us, including how we collect, process, protect and share personal information.

The data controllers of your personal information will be TowerBrook Capital Partners L.P. and TowerBrook Capital Partners (U.K.) LLP. If you have any questions regarding TowerBrook’s use of your personal information, or this policy, please contact compliance@towerbrook.com.

We rely on various legal bases under applicable data protection legislation in order to process your personal information, including our legitimate interests, contractual necessity and as required by law. Section 2 of this policy explains the applicable legal basis under which we process your personal information for each purpose.

If we require your personal information due to a legal requirement or obligation, or in order for us to perform a contract with you, we will make you aware of this at the time we collect your personal information (unless we are restricted from doing so by law, rule or regulation), and the possible consequences of you failing to provide this personal information (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations).

1. How we obtain your personal information

Information you provide to us
We collect your personal information when you decide to interact with us and we only collect the information reasonably necessary to carry out our business (see section 2 of this policy which explains why we use your personal information). You can provide us with personal information via email, mail and telephone, which includes, without limitation, address, job title, position and email address.

Information provided by third parties
We also process limited personal information in relation to companies that TowerBrook may consider investing in or purchasing. This personal information is obtained via third parties (i.e., the company in question).

2. Why we use your personal information

We will use your personal information for the following purposes on the following legal bases:

Purpose Legal Basis
To provide you with the services or financial products you have requested Contractual necessity
To keep a record of your relationship with us Legitimate interest
To verify your identity Legal purposes and legitimate interest
To conduct due diligence activities in connection with an actual
or prospective corporate transaction or investment which
TowerBrook is party to		 Legitimate interest
Fraud and abuse prevention Legal purposes and legitimate interest
Litigation management and conducting internal audits and investigations Legal purposes and legitimate interest
To send you information about TowerBrook and to keep you informed of
our products and services in which you might be interested (if you have
provided your consent to us doing so,or based on our legitimate interests
where we have an existing relationship with you and we wish to contact
you about similar products and services in which you may be interested)		 Consent or legitimate interest

No automated decision making, including profiling, is used when processing your personal information.

3. Who we share your personal information with

We share your personal information with our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including, without limitation, DealCloud (for CRM purposes), Syncplicity (for file sharing purposes), Amazon Web Services (who provide cloud storage), AES (for IT security purposes) and professional advisors (including, without limitation, any legal, compliance, accounting and financial advisors). We ensure that key parties that provide a service to, or for us, enters into an agreement with us and meets our standards for data security.

We will share your personal information with governmental and regulatory bodies (e.g., the FCA, SEC, FINRA, IRS and HMRC) where required for legal, investigatory, regulatory, national security or for the purposes of public importance.

We will also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, or other disposition of all or a portion of our business, assets or shares.

4. How we keep your personal information secure

We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in section 2 of this policy, unless a longer retention period is required by law (e.g., 6 years from the date of collection, as required under FCA regulations). We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact us at compliance@towerbrook.com.

5. Transfer of your personal information

To the extent we transfer your personal information to countries located outside of the European Economic Area (“EEA”) or the United Kingdom (the “UK”), such transfers will be made in accordance with applicable data privacy laws.

TowerBrook Capital Partners L.P. and TowerBrook Capital Partners LLC (our affiliate) are located in the US. To the extent any personal information is transferred from a TowerBrook entity within the EEA or the UK to a TowerBrook entity outside the EEA, this transfer is legitimised and your personal information is adequately protected under the terms of the EU controller-to-controller model contract clauses or, in respect of transfers of personal data outside the UK, such other clauses which may be approved by the Government of the UK.

6. Your rights

You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us at compliance@towerbrook.com

  • Access: You have the right to ask for a copy of the personal information that TowerBrook holds about you free of charge. However, we may charge a ‘reasonable fee’ if we consider that your request is excessive to help us cover the costs of locating the information you have requested.
  • Correction: You may notify us of changes to such your personal information if it is inaccurate or it needs to be updated.
  • Deletion: If you consider that we should not be holding or processing your personal information any longer, you may request that we delete it. Please note that this may not always be possible due to legal obligations
  • Restrictions on use: You may request that we stop processing your personal information (other than storing it) if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information override your own rights.
  • Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
  • Portability: If you wish to transfer your personal information to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
  • Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, and you no longer wish to consent to us doing so, you may contact us to let us know that you withdraw that consent.

7. Cookies

This website uses cookies. For further information with regards to what types of cookies are used, why and how to turn such cookies off or on, please see our Cookie Policy.

8. How to contact us

For any questions regarding TowerBrook’s processing of your personal information (including your rights as explained at section 6 of this policy) please contact us at compliance@towerbrook.com

9. Complaints

Should you wish to lodge a complaint with regards to how your personal information has been processed by TowerBrook, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.