Scope and purpose

PAI Partners SAS, PAI SAS and PAI Partners S.à r.l., their subsidiaries and affiliates (collectively, solely for the purpose of this Privacy Notice: “PAI” or “PAI Partners” or “we” or “us” or “our”), acting as data controller, are committed to protecting and respecting the privacy of any individual and ensure the protection of any personal information we collect from you and further process.

Personal Data is a critical asset and PAI is accountable for processing such information with the requisite care, integrity and discretion so as to provide appropriate protection to Personal Data and comply with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and any applicable local data protection laws and regulations.

PAI has established an external personal data protection policy considering the nature, scope, context and purposes of Personal Data processing as well as the risks of varying likelihood and severity (proportionality principle) for rights and freedoms of natural persons posed by the processing. This public notice (the “Privacy Notice”), both available on PAI website and PAI ESG Lab, intends to provide you with the summary information about how PAI collects, processes, protects and retains your personal data, as well as the reasons for their use and sharing. This Privacy Notice also aims at informing you of your rights regarding the collection and processing of your personal data and the procedures for exercising your rights.

All data protection terms used in this Privacy Notice have the meaning as set out in the GDPR.

Personal data protection

What is considered as personal data?
“Personal Data” is defined under GDPR regulation as any information relating to an identified or identifiable natural person (“Data Subject”), an identifiable natural person being a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Whose data do we collect?
We collect the personal data of (i) visitors of the PAI premises or website and PAI ESG Lab, (ii) PAI employees, (iii) job applicants, (iv) our investors, co-investors and their representatives as well as (v) other professional contacts (hereinafter together referred as the “Partners”).

What personal data do we collect and for which purpose and legal basis?
We collect mainly, and where relevant only the following data for the following purposes:

  • Purpose: Corporate Marketing (visitors, PAI employees)
    Legal basis: Legitimate interest. Performance of contract/Consent (right to use image)
    Personal data: First name, last name, professional email address, phone number, IP address, data collected from cookies including audience and navigation measurements, pictures
  • Purpose: Product Marketing (visitors)
    Legal basis; Legitimate interest. Performance of contract/Consent (right to use image). Consent (for newsletter)
    Personal data: First name, last name, professional email address, phone number, IP address, data collected from cookies including audience and navigation measurements
  • Purpose: Recruitment (job applicants)
    Legal basis: Legitimate interest. Consent (CV retention)
    Personal data: First name, last name, personal email address, personal phone number, gender, nationality, CV, academic and professional background, diplomas, salary information and expectations, family situation, date of birth, where applicable personality/skills assessments, background checks, where applicable criminal records, recruitment firms reports, interview reports, disabled status, IP address, data collected from cookies including audience and navigation measurements
  • Purpose: Relationship with investors (investors, co-investors, representatives)
    Legal basis: Legitimate interest (potential investors). Performance of contract (current investors). Performance of contract/Consent (right to use image)
    Personal data: First name, last name, professional email address, professional phone number, unique investor ID, function, profession, field of activity, pictures and video footage, data relating to the professional, economic and/or tax situation

Furthermore, to operate our websites, remember your preferences, improve your experience as well as analyze the performance of our websites, we collect certain personal data, using cookies,  about our website users– for further details in that regard please refer to our Cookie Policy.

Should you refuse to share with us some of required personal data, it might prevent you to the benefit of part of the services provided by PAI and/or functionalities of our websites.


How do we protect the Personal Data we collect? PAI has implemented appropriate technical and organisational security measures based on the risk for your rights and freedom to protect the confidentiality and integrity of your Personal Data and to prevent them from being, accidentally or unlawfully, altered, damaged, destroyed or disclosed to/accessed by unauthorised third parties. The same level of protection is contractually imposed by PAI on its services providers which process your Personal Data acting as Processors (on behalf of PAI). In addition, any PAI employee who, in the course of their work, might have access to your Personal Data agree to hold it in the strictest confidentiality. However, although we take all reasonable measures to protect your Personal Data, no transmission or storage technology is totally infallible. In accordance with the GDPR, in the event of a Personal Data breach likely to result in a high risk to individuals’ rights and freedoms, we undertake to notify the competent data protection authority and, when required by the GDPR, the relevant Data Subjects (individually or collectively as appropriate).


With whom do we share the Personal Data we collect? PAI may share your Personal Data with the following categories of internal recipients:

  • PAI’s employees working in the Communication team, ESG team, Finance team and Compliance team;
  • PAI’s internal contractors working in the IT team;
  • PAI’s suppliers who provide us with software and hardware used on PAI website or PAI ESG Lab;
  • PAI’s employees in charge of recruitment and Human Resources management who will have access to Personal Data regarding candidates.

Your Personal Data will not be sold to third parties.

However, we may have to disclose your Personal Data to the members of PAI group, including PAI subsidiaries and affiliates, so that the group may adopt an integrated approach to its Partners. Group members may use your personal information only for the purposes specified above.

We also may disclose your information to third parties if so required or authorised by the law or regulations (i.e. auditors, government and law enforcement agencies or regulators), to certain service providers, such as our custodians, who need to know such information to perform their services, to bona fide professional advisers and other third parties to the extent (i) such disclosure is reasonably required to assist PAI with its diligences in order to evaluate and comply with its legal, regulatory, tax requirements and (ii) the relevant third parties are informed of the strictly confidential nature of the disclosed personal information and have committed to ensure an equivalent level of protection in a written dedicated agreement or clause.

Some of these recipients may be located outside the European Union and have access to all or part of the personal information we collect. Where this is the case, we guarantee that your personal data will be protected to the very highest standards, with the implementation of appropriate safeguards, including through standard contractual clauses of the European Commission where required.


How long do we keep your Personal Data? We ensure that Personal Data is retained according to defined retention periods per purpose of processing for no longer than necessary given the purpose(s) of their processing, as authorized under the applicable law or regulation.

The retention period therefore varies depending on that purpose, as well as on any applicable legal provisions stipulating a specific retention period for certain types of data, any statute of limitation periods, and the recommendations of the CNIL (Commission nationale de l’informatique et des libertés) for certain types of data processing.

 

Your personal data protection rights

How to access, update and correct your Personal Data?
In accordance with applicable data protection laws and regulations, you have the rights of access, rectification, erasure, restriction of processing, objection, portability of your personal data we hold about you as well as the right to define the fate of your data after your death. When the Processing is based on your consent, you have the right to withdraw your consent at any time.

You can exercise these rights by emailing dataprotectionofficer@paipartners.com. In order for us to be able to answer your request, you must communicate us the following necessary identification data: name, e-mail and any other identity document or follow identity verification process to confirm your identity.

In the event of a breach of the applicable Personal Data protection laws and regulations by PAI you may lodge a complaint with the French data protection supervisory authority:

Commission Nationale de l’Informatique et des Libertés (CNIL)
3 Place de Fontenoy
TSA 80715
75334 PARIS CEDEX 07
or https://www.cnil.fr/fr/plaintes

 

Changes to the Privacy Notice

We may update this Privacy Notice from time to time without prior notice.
We encourage you to regularly check PAI’s Site to ensure that you are aware of the last updated version.
This Privacy Notice was last updated in February 2021 and replaces and supersedes any prior version of our Privacy Notice.


Contact us

If you have any questions about our Privacy Notice or if you have any questions or concerns about how PAI processes personal data and maintains the protection of your personal data, please contact us at: dataprotectionofficer@paipartners.com