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Privacy Policy

Blue Water Energy LLP (“Bluewater”, “we” or “us”) has created this Privacy Policy in order to demonstrate our commitment to the protection of personal information (i.e. any information relating to a living individual and from which that individual can be identified). The purpose of this Privacy Policy is to inform you about the types of information we gather about you (when you visit our website and through your other interactions with us), how we may use that personal information and whether we disclose it to anyone. We will only use personal information which is provided to us, or otherwise obtained by us, as set out in this Privacy Policy. This Privacy Policy applies to all of Bluewater’s group companies but for the avoidance of doubt, does not cover any of our portfolio companies who have their own policies and procedures. 

We will ensure that your personal information is handled in accordance with any legislation applicable from time to time relating to the processing of personal information and/or privacy. By using our website and by otherwise interacting with us, you acknowledge that we may collect, use and transfer your personal information as set out in this Privacy Policy. This Privacy Policy may be amended at any time without notice. If you are not happy with the terms of this Privacy Policy or any amendments made, you should not access or use our website and/or our services. 

Personal information means any information relating to a living individual and from which that individual can be identified. We have set out below (by reference to each category of individual about which we may process personal data) the personal information that we may process, the purposes for that processing and the legal bases on which we may rely to process this information. 

a. Personal information of general business contacts

If you have had contact with Bluewater, for example through emailing us or meeting a Bluewater representative, we will collect and store certain personal information that may include: 

  1. your name;
  2. your job role;
  3. your contact details that you provide to us; and
  4. notes taken during any meeting that Bluewater have had with you.

 

We will collect and store this personal information for the purposes of:  

  1. contacting you and arranging meetings regarding your relationship with Bluewater;
  2. maintaining records of business contacts;
  3. sharing with you information that is relevant to your relationship with Bluewater (including inviting you to presentations and events that may interest you in the context of your relationship with Bluewater); and
  4. carrying out internal investigations.

 

Our legal basis for collecting, storing and processing this personal information is that it is necessary for our legitimate interests of running and promoting our business. 

b. Personal information of potential investors (Individuals or Beneficial Owners)

If you are a potential investor, or beneficial owner of a fund, vehicle or entity, making contact with Bluewater with the intention of making an investment (or enquiring into an investment you may potentially make) with Bluewater, we will collect, process and store certain personal information that may include: 

  1. your name;
  2. your contact details that you provide to us;
  3. history of previous investments that you have made;
  4. proof of identification and address (including passports, driving licences and utility bills); and
  5. any notes that we take in any meetings with you regarding your potential investment.

 

We will collect, process and store this personal information for the purposes of: 

  1. contacting you and arranging meetings regarding your potential investment;
  2. performing client due diligence and “know your client” checks;
  3. maintaining a record of potential investors;
  4. sharing with you information that is relevant to your potential investment (including inviting you to presentations and events that may interest you in the context of your interest in the investment); and
  5. carrying out internal investigations.

 

Our legal bases for collecting, processing and storing this personal information are that it is necessary for:  

  1. our legitimate interests of running and promoting our business; and
  2. complying with our legal and regulatory obligations.

c. Personal information of individual investors (Individuals or Beneficial Owners)

If you are making or have made investments, or are the beneficial owner of a fund, vehicle or entity making or has made investments, with Bluewater, we will collect, process and store certain personal information (including special category personal data) that may include: 

  1. your name;
  2. your contact details that you provide to us;
  3. your home address;
  4. proof of identification and address (including passports, driving licences and utility bills);
  5. information of political affiliations;
  6. any financial information you provide to us regarding your investment (including bank account details and proof of source of funds); and
  7. any notes that we take in any meetings with you regarding your investment.

 

Where another individual makes an investment on your behalf, we may collect some of the above information from them to effect the transfer of the investment to you, such as your name and contact details. 

We will collect and store this personal information for the purposes of: 

  1. contacting you and arranging meetings regarding your investment;
  2. facilitating payment to you of dividends and other amounts relating to your investment;
  3. performing client due diligence and “know your client” checks;
  4. maintaining a record of investors;
  5. sharing with you information that is relevant to your investments (including inviting you to presentations and events that may interest you in the context of your investments); and
  6. carrying out internal investigations.

 

Our legal bases for collecting, processing and storing this personal information are that it is necessary for: 

  1. our legitimate interests of running and promoting our business, and ensuring effective communications with our investors;
  2. complying with our legal and regulatory obligations;
  3. fulfilling the contract that we have entered into with you;
  4. the establishment, exercise or defence of legal claims; and
  5. reasons of substantial public interest.

d. Personal information of directors and corporate secretaries of institutional investors

If you are a director or a corporate secretary of an institutional investor that is making or has made investments with Bluewater, we will collect and store certain personal information (including special category personal data) that may include: 

  1. your name;
  2. your job role;
  3. your home address;
  4. proof of identification and address (including passports, driving licences and utility bills);
  5. information of political affiliations;
  6. financial Information; and
  7. your contact details that you provide to us.

We will collect and store this personal information for the purposes of: 

  1. performing client due diligence and “know your client” checks on the institutional investor, its directors and corporate secretary; and
  2. carrying out internal investigations.

Our legal bases for collecting, processing and storing this personal information are that it is necessary for:  

  1. complying with our legal and regulatory obligations;
  2. the establishment, exercise or defence of legal claims; and
  3. reasons of substantial public interest.

e. Personal information of job applicants

If you are applying for a job role with Bluewater, we will collect and store certain personal information that may include: 

  1. your name;
  2. your job role;
  3. your home address;
  4. your education history;
  5. your employment history;
  6. details of any criminal offences committed or any proceedings for any offence committed or alleged to have been committed by you;
  7. proof of identification and address (including passports, driving licences and utility bills);
  8. diversity data (including details of your race, religion and economic background);
  9. i. your contact details that you provide to us; and
  10. information relating to you that we collect from references that you have provided to us.

 

We may collect this personal information from past employers and other third parties (such as reference agencies) concerning your employment history where you apply for a job from us. 

We will collect and store this personal information for the purposes of:  

  1. facilitating our recruitment process;
  2. making a decision in respect of your recruitment;
  3. contacting you in respect of the recruitment process;
  4. retaining a record of job applicants;
  5. checking your legal entitlement to work for us;
  6. equal opportunities monitoring; and
  7. carrying out internal investigations.

 

In addition to those parties set out in section 1 of this Privacy Policy, we may share your personal information with reference and employment screening agencies that provide their services to Bluewater. 

Our legal bases for collecting, processing and storing this personal information are that it is necessary for:  

  1. our legitimate interests of running our business and administering transactions that we enter into;
  2. complying with our legal and regulatory obligations;
  3. reasons of substantial public interest;
  4. the establishment, exercise or defence of legal claims; and
  5. the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment.

We may also rely on your express consent to process certain personal information, such as your diversity data. 

Unless we need to retain such information for a longer period to comply with our legal obligations, in the event that you are unsuccessful, we will retain your details for no longer than 1 year after the end of the relevant recruitment process. 

f. Personal information of individuals at suppliers

If you are an employee, director or contractor of a supplier or advisor with which Bluewater contracts (or intends or prospective enquires to contract), we will collect and store certain personal information that may include: 

  1. your name;
  2. your job role; and
  3. your contact details that you provide to us.

 

We may collect this information directly from your employer in connection with the service that they provide to us in connection with the service we provide to our members. 

We will collect and store this personal information for the purposes of:  

  1. administering and maintaining records of services or advice that we have received and commissioning further services from the supplier/advisor entity; and
  2. carrying out internal investigations.

 

Our legal basis for collecting, processing and storing this personal information is that it is necessary for our legitimate interests of running and promoting our business. 

g. Personal information of management teams and other staff of Bluewater investee companies

If you are part of a management team or an employee or contractor of a Bluewater investee company, we will collect and store certain personal information that may include: 

  1. your name;
  2. your job role;
  3. information relating to your current employment with the Bluewater investee company;
  4. your employment history;
  5. your education history;
  6. details of any criminal offences committed or any proceedings for any offence committed or alleged to have been committed by you;
  7. proof of identification and address (including passports, driving licences and utility bills);
  8. diversity data (including details of your race, religion and economic background); and
  9. i. your contact details that you provide to us.

 

We will collect and store this personal information for the purposes of: 

  1. assessing potential transactions;
  2. maintaining records of investments;
  3. administering any transaction that we enter into;
  4. assessing your suitability for involvement in a transaction, including by verifying your identity;
  5. assessing and managing continuing risks within the investee company;
  6. safeguarding our legal rights and interests;
  7. seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants;
  8. providing periodic updates and communicating with you in respect of the investee company and any related transactions; and
  9. i. carrying out internal investigations.

 

Where we are conducting due diligence on prospective investee companies or deciding whether to invest in third parties we may also receive personal information concerning key personnel. 

In addition to those parties set out in section 1 of this Privacy Policy, we may share your personal information with: 

  1. financial intermediaries;
  2. credit reference agencies; and
  3. other persons that have an interest or involvement in, or who are considering an interest or involvement in, a Bluewater transaction (including co-investors and investors in Bluewater’s funds).

Our legal bases for collecting, processing and storing this personal information are that it is necessary for:  

  1. our legitimate interests of running our business and administering transactions that we enter into;
  2. complying with our legal and regulatory obligations;
  3. reasons of substantial public interest;
  4. the establishment, exercise or defence of legal claims; and
  5. the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment.

We may also rely on your express consent to process certain personal information, such as your diversity data.  

h. Personal information of any individuals that access our website and sign up to our newsletter and/or agree to receive marketing updates from us

If you provide your details to us through our website by signing up for our newsletter or if you consent to receive marketing from us, we will collect and store your name, your email address and (where relevant) your marketing preferences. 

We will collect and store this personal information for the purposes of:  

  1. sharing our newsletter, our marketing communications and related information that we think may interest you; and
  2. carrying out internal investigations.

 

Our legal basis for collecting, storing and processing this personal information is:  

  1. you have consented to receiving our newsletter by providing your email address to us for this purpose or otherwise consented to receiving marketing communications from us; and
  2. we are otherwise entitled to use your personal information for marketing purposes for our legitimate interests of promoting our business.

i. Individuals who are the emergency contact or next of kin of our staff members

If you are listed as an emergency contact or next of kin of any of our staff members in relation to their employee benefits arrangements, we will collect and store certain personal information that may include: 

  1. your name;
  2. your telephone number;
  3. your email address; and
  4. your home address.

 

We will collect this information about you from the relevant staff members that provide this information. 

We will collect and store this personal information for the purposes of: 

  1. administrating our staff members’ employee benefits arrangements; and
  2. contacting you in the event of any emergency affecting the staff member.

 

Our legal bases for collecting, storing and processing this personal information are that it is necessary for: 

  1. our legitimate interests of ensuring the safety and wellbeing of our staff members; and/or
  2. protection of the vital interests of the staff member.

 

Certain personal information may be collected passively through the use of our website, including your Internet protocol address, browser type, domain names, times, and operating system. We may also use session and persistent cookies and navigational data (such as URLs) to gather information regarding the date and time of your visit and the information and services for which you searched and which you viewed. We do not intentionally gather personal information about visitors who are minors. 

Where you have explicitly consented at the time we collected your personal information to receive marketing from us or where we otherwise have a right to do so (such as where we are able to rely on our legitimate interests to promote our business to a business contact (as opposed to a consumer)), we may also use your personal information to enable us to get in contact with you to let you know about any of our services that may be of interest to you and/or inform you about important changes or developments to our services by email. 

If you change your mind about us using your personal information in the ways described in this Privacy Policy, please let us know by contacting us at datamonitor@bwenergy.com. You may also opt out of receiving marketing emails from us by following the instructions outlined in the email. 

Where information is obtained from third party sources, the third party is responsible for informing you that they have shared your personal information with us, directing you to this Privacy Policy and obtaining any relevant consents from you to ensure you are happy with the ways in which your personal information will be used. However, once we are holding it, we will only handle any person’s personal information in accordance with this Privacy Policy. 

1. Disclosure of Personal Information

Any personal information provided to Bluewater will be transferred to and stored on Bluewater’s cloud-based servers within Europe. Backups of our data are held on cloud-based servers within the European Economic Area or within countries that has been confirmed by the UK Government to provide adequate protection to personal information, or have agreed (by way of written contract incorporating specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK) to provide all protections to your personal information as required by applicable data protection legislation. Any personal information provided to a fund will be transferred to and stored in Guernsey. We take steps to protect your personal information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. 

Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your personal information with certain third parties, such as our delegates, professional advisors, service providers, regulatory bodies, law enforcement agencies, auditors, technology providers and any duly authorised agents or related, associated or affiliated companies of the foregoing for the same purposes. 

By submitting your personal information to us, you acknowledge that such third parties may receive and process your personal information. We ask all third parties to treat your personal information securely and in accordance with this Privacy Policy and will take reasonable steps to enforce this. 

Except as otherwise stated in this Privacy Policy, we do not generally trade, rent, or share your personal information with third parties unless you ask us to do so. If our company or our assets are acquired by another company, that company will possess the personal information collected by us and it will assume the rights and obligations regarding your personal information as described in this Privacy Policy. We may disclose your personal information if we believe in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas, court orders or warrants served on Bluewater; or (b) to protect and defend the rights or property of Bluewater or third parties. 

In processing your personal information, it will sometimes be necessary for us to transfer your personal information outside the UK to our staff and our third-party service providers. It may also be accessed by staff operating outside the UK who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and relevant data protection legislation when it is processed in, or otherwise accessed from, a location outside the UK. This means that we will only transfer your personal information outside the UK including to our group companies / funds if the receiving party (a) is situated in a country that has been confirmed by the UK Government to provide adequate protection to personal information, (b) has agreed (by way of written contract incorporating specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK) to provide all protections to your personal information as required by applicable data protection legislation or (c) we have your explicit consent to do so (such as where you have requested a service from one of our funds situated outside the UK). Where any transfer takes place under a written contract, you have the right to request a copy of that contract and may do so by contacting us at datamonitor@bwenergy.com.  

By submitting your personal information to us, you acknowledge this transfer, storing or processing of your personal information. 

 

Bluewater is committed to protecting the security of your personal information. We use a variety of industry-standard security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. Even though Bluewater has taken significant steps to ensure that your personal information is not intercepted, accessed, used, or disclosed by unauthorized persons, you should know that Bluewater cannot fully eliminate security risks associated with personal information. 

If you use our website, we may collect details such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access our website. We collect this personal data by using cookies and other similar technologies.  

For more information, please see our Cookie Policy. 

We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy. The personal data that we collect from you will be retained for as long as necessary to fulfil the purposes for which the information was collected or as required by law. 

You have the right to ask us not to process your personal information for marketing or research purposes. If we intend to disclose your personal information to any third party for marketing purposes, we will seek your explicit consent prior to any such transfer. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal information. You can also exercise the right at any time by contacting us at datamonitor@bwenergy.com. 

You are entitled to know some details about the personal information we hold about you and how that information is processed. If you would like to request this, please contact us at datamonitor@bwenergy.com and we will provide you with the information to which you are entitled. 

You can also ask us to: (a) make any changes to ensure that any personal information we hold about you is accurate and up to date; (b) erase or stop processing any personal information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some circumstances, transfer any information we hold about you to a specified third party. If you wish to exercise any of these rights, please contact us at datamonitor@bwenergy.com. 

If you have any questions or complaints regarding the use of or your rights regarding your personal information, please contact Bluewater at datamonitor@bwenergy.com. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues. 

Our website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any personal information via these websites.

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