Sands Capital Management, LLC Privacy Notice
1. PURPOSE AND SCOPE OF THIS PRIVACY NOTICE
This privacy notice (“Notice“) describes how we collect, use, and share the information (“Personal Data“) of individuals who visit our website (www.sandscapital.com) (“Website“). For the purposes of this Notice, the controller of your Personal Data is Sands Capital Management, LLC (“Sands Capital“, “we“, “our” and “us“) of 1000 Wilson Boulevard, Suite 300, Arlington, Virginia 22209, USA.
IMPORTANT: Where you provide Personal Data about other individuals (e.g. your representatives), you agree that you are responsible for ensuring that such individuals know their Personal Data will be used by Sands Capital in accordance with this Notice.
If you have any queries, concerns, or would like to exercise any of your data protection rights arising from this Notice, please contact our Client Service Team at privacyquestions[at]sandscap.com.
2. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?
When using our Website, you may voluntarily provide Personal Data about yourself, including your first name, last name, name of company where you work, e-mail address, your username and password, and any other information you choose to provide. For example, we collect this Personal Data when you log in via the ‘Limited Partner Portal’, contact us, or interact with us for any other purpose.
We (and other entities) automatically collect Personal Data relating to your interactions with us and our Site, including browser type, IP address, pages visited and other activities on the Website, device type, and time and date of visit, and other information we collect through the use of cookies and similar technology. See the “Digital Advertising & Analytics” section of this Notice to learn more about the use of this information and the choices available to you.
Sands Capital uses cookies to assist with these efforts. Read our Cookies Policy for more information.
3. HOW & WHY DO WE USE YOUR PERSONAL DATA?
We may use your Personal Data for any lawful purposes, including for the following Legal Bases and Purposes:
| Legal Basis | Purposes |
|---|---|
| Legitimate Interests | We will process your Personal Data for the purposes of our legitimate interests, for Website improvements and functionality, including:
IMPORTANT: when we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. You have certain rights when we process your Personal Data on this basis, such as the right to object. For more information on exercising this right please see section 7 of this Notice (Your Data Protection Rights). |
| Legal Obligation | We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject under European Union Member State laws or regulatory requirements, including in connection with warrants/notices issued by law enforcement, a court of law or other regulatory authorities in the context of inquiries or investigations. |
| Consent | Where we collect your Personal Data by using cookies on the Website that are not necessary for the Website to operate, we require your consent to do so. Please see our Cookies Policy for more information. |
IMPORTANT: If you do not provide us with such Personal Data so that we can process it for these purposes, we may not be able to make the Website available to you or engage or interact with you.
We may process personal data by both automated and manual means. In addition to the uses described above, we may use Personal Data in other ways for which we provide specific notice at the time of collection.
We do not sell your personal information and we do not let our Recipients sell your information.
4. SHARING OF YOUR PERSONAL DATA
- With our staff, agents and contractors;
- With staff, agents or contractors of our group companies (within the Sands Capital group);
- With any party you have given us permission to speak to (e.g. your agents or representatives);
- With other financial companies and their agents;
- With third-party service providers who process information on our behalf:
- in relation to our products or services; and
- in relation to our Website or business (e.g. our CRM provider, analytics & search engine providers that assist us in the improvement and optimization of our Website);
- Pursuant to a subpoena, court order, governmental inquiry, law enforcement agencies, regulatory authorities, or other legal process or as otherwise required by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or entity;
- With our external professional advisors such as our legal advisors and consultants; and
- With your consent or as otherwise disclosed at the time of data collection or sharing.
5. DIGITAL ADVERTISING & ANALYTICS
We may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Website and other sites or apps over time, including information about relationships among different browsers and devices.
You may visit the DAA Webchoices tool at www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. You can also exercise choices regarding interest-based advertising on your mobile device by downloading the appropriate version of the DAA’s AppChoices tool at https://youradchoices.com/appchoices.
If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.
We may also work with third parties that collect data about your use of the Website and other sites or apps over time for non-advertising purposes. Sands Capital uses Google Analytics and other third-party services to improve the performance of the Website and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Site, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.
Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Website may not function as intended.
6. TRANSFERS OF YOUR PERSONAL DATA
We are located in the United States of America (“USA”), meaning we may process your Personal Data outside the United Kingdom (“UK”) or European Economic Area (“EEA”). In operating the Website, we may share your Personal Data with certain Recipients who are also located in the USA or other countries with laws and practices that do not contain equivalent data protection rights for your Personal Data as those pursuant to the General Data Protection Regulation (“GDPR”). Where such processing or transfers occur, we ensure that appropriate safeguards are in place by making it our policy that: a) processing does not occur without our prior written authority and meets the standards of the GDPR; and b) that, where applicable, an appropriate transfer agreement is in place to protect your Personal Data (such as the European Commission’s Standard Contractual Clauses or other approved transfer mechanisms approved by the European Commission and supervisory authorities and/or the UK Information Commissioner’s Office).
7. USA STATE PRIVACY RIGHTS
California residents have certain rights under state privacy law with respect to the Personal Data we collect. If you are a resident of such state, please know this Notice contains disclosures required by law and explains rights that may be available to you.
Personal Information We Collect and Disclose. In the preceding 12 months, we collected and disclosed the following categories of Personal Data:
- Personal and online identifiers (such as first and last name, email address, or unique online identifiers);
- Recordkeeping information (such as physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, or health information);
- Characteristics of legally protected classifications (such as race or gender);
- Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement);
- Professional or employment-related information;
- Education information;
- Inferences drawn from the above information about your predicted characteristics and preferences; and
- Other information about you that is linked to the personal information above.
Categories of Sources. We collect Personal Data from the following categories of sources:
- You;
- Our affiliates and joint venture partners;
- Our business partners;
- Our service providers; and
- Advertising companies and networks.
Our Purposes for Processing Personal Data. We use and disclose the Personal Data we collect for our commercial and business purposes, as further described above in the “How & Why Do We Use Your Personal Data?” section of this Notice.
We may use and share aggregated and deidentified information to the extent permitted by applicable law. When we use deidentified information, we maintain and use the information in deidentified form and do not attempt to reidentify it, except to check whether our deidentification processes satisfy the requirements of applicable law.
Recipients of Personal Data. We disclose the categories of Personal Data designated above to the categories of third parties listed in the “Sharing of Your Personal Data” section of this Notice for commercial and business purposes.
8. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We retain the Personal Data we collect for as long as reasonably necessary to accomplish the purposes described in the “How & Why Do We Use Your Personal Data?” section of this Notice. In most instances, we retain Personal Data for the time periods set out below:
- Support & Service queries/requests: the length of time it takes to address or conclude your query or request and, in some cases, a reasonable period of time after that to allow for follow-up actions;
- Marketing details: generally, indefinitely until you request a change through our preference center; and
- Legal obligation compliance: the period specified by the legislation (if any) or a reasonable period of time to demonstrate compliance with the legal obligation.
See our Cookies Policy for more information.
9. YOUR DATA PROTECTION RIGHTS
You have a number of rights in relation to your Personal Data. Depending on your jurisdiction of residence, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations.
- The right to access the Personal Data we hold about you;
- The right to correct inaccuracies in the Personal Data we have collected about you;
- The right to request that we delete Personal Data;
- Depending on your jurisdiction, you may have the right to restrict or object to our processing of Personal Data;
- Under certain circumstances, to receive Personal Data about you that we store and transmit to another without hindrance from us, including requesting that we provide Personal Data directly to another, i.e., a right to data portability;
- Where we previously obtained your consent, the right to withdraw consent you previously provided to processing Personal Data; and
- The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by California’s privacy law.
To exercise these rights, please click here to fill out our privacy request form, or email us at privacyquestions[at]sandscap.com.
Verification. Please also note that we may need to verify your identity when you exercise your data protection rights. We will require
you to provide, at a minimum, your first and last name, zip code, phone number, and email address.
You have the right to lodge a complaint with the Data Protection Commission with regard to our processing of your Personal Data if your Personal Data rights are covered under GDPR. See https://forms.dataprotection.ie/contact.
10. MINORS’ RIGHTS
We do not have actual knowledge that we sell the Personal Data of minors under 16 years of age.
11. CHANGES TO THIS NOTICE
If we amend this Notice, in whole or part, any changes will be posted on the Website.
If at any time we decide to use your Personal Data for a purpose significantly different from that stated in this Notice, or otherwise disclosed to you at the time it was collected, we will notify you, and you will have a choice as to whether or not we use your Personal Data for such a new purpose.
12. CONTACT US
If you have any questions, comments or concerns about the way your Personal Data are being used or processed by Sands Capital, please submit your question, comment or concern by e-mailing the Client Service Team at: privacyquestions[at]sandscap.com.