WHAT PERSONAL DATA WE MAY PROCESS?
SIA Livonia Partners (Livonia) is an investment advisor of alternative investment fund managers that are investing in companies in the Baltic region. In this privacy notice we define most of the circumstances when we may process personal data of other persons who are not our employees.
The most likely scenarios where Livonia may process any personal data is in the context of our responsibilities for due diligence and later management of target companies that we have selected as candidates for investing and in fulfilment of our know-your-client (KYC), anti-money laundering and any sanctions regimes legal obligations or for personnel recruitment purposes for ourselves or for key positions in our portfolio companies. We may also keep for some time contact details of individuals (managers and shareholders) of target companies with whom we expect to conduct business and relevant information about our business communication with them.
The types of personal data we may process during a due diligence process of a target company may include names, surnames, salary data, work agreements, CVs of management and key employees of the target company.
Legal obligations in the area of anti-money laundering require us as a financial services company to make every effort to verify the identity, suitability and risks involved with setting up and maintaining business relationships with a range of our business partners such as, investors in funds managed by us, business partners from whom an investment (our portfolio company) is acquired or to whom a portfolio company is sold, and other shareholders of the portfolio company. In such cases we process information that may identify our clients or business partners who are natural persons and identifying information of representatives and beneficial owners of our clients or business partners who are natural persons. The types of personal data we may process for KYC purposes are determined by relevant applicable laws and regulations. In addition to identification data, other information may involve such data as information about business operations of our clients and business partners as well as any origin of funds for the transaction.
For recruitment purposes we will process the usual personal and contact information, CVs, and other documents regarding the qualifications and any relevant additional documents that may have been submitted by the applicants themselves.