1.1 This privacy policy (‘Privacy Policy’) explains how Mediterrania Capital Partners collects, stores, shares, protects and uses personal information of our website visitors, business contacts, suppliers, professional advisors, investors, actual and potential sponsors and management teams involved in a transaction or potential transaction with Mediterrania Capital Partners and/or funds that it manages or advises and alumni. It also describes the cookies we may use and send to your computer or mobile device.
1.2 In this Privacy Policy ‘Mediterrania Capital Partners, ‘we’, ‘us’ and ‘our’ refer to Mediterrania Capital Partners, Ltd.
1.3 The data controller of the personal data is Mediterrania Capital Partners, Ltd. with registered office at WhiteHall Mansions – Level 2, Ta’ Xbiex Wharf, Ta’ Xbiex, 1026 XBX, Malta. VAT No. MT2149-0816
1.4 Personal information means any information that we hold about you from which you can be identified either directly or indirectly and it may include your name; contact details; job title, employer organisation, qualifications, CV, employment history and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as your passport), references provided by third parties, and results of other due diligence carried out.
2.1 We will collect and store your personal information when you interact with our website, when you have had contact with Mediterrania Capital Partners through introductions or meeting an Mediterrania Capital Partners representative or when corresponding with us in relation to a transaction that Mediterrania Capital Partners and/or the funds it manages or advises enter into, or a potential transaction that Mediterrania Capital Partners is considering or in respect of the funds that Mediterrania Capital Partners manages or advises.
2.2 We collect personal information in writing, by telephone, by e-mail and by online registrations. We may receive information from third parties who collect personal information from you and pass it on to us for example where we conduct verification or anti-money laundering checks on sponsors and management teams for prospective transactions.
3.1 If you are a business contact we will hold limited amounts of personal information about you such as your name, contact details, job title, employer organisation and perhaps your CV.
3.2 If you are a supplier, consultant or professional advisor, we will hold personal information about you including the information set out in paragraph 3.1, as well as your date of birth, bank account details and VAT number (to the extent applicable).
3.3 If you are a job applicant, we may hold information you have provided to us in your CV, application form and covering letter including the information set out in paragraph 3.1 as well as your date of birth, gender and any information you provide to us as during an interview. We may also hold special categories of more sensitive personal information such as your race or ethnicity, information about your health including any medical condition and sickness records.
3.4 If you are a sponsor or a member of an actual or potential management team in respect of a transaction and/or potential transaction that Mediterrania Capital Partners and/or funds managed or advised by Mediterrania Capital Partners enter into or consider, personal information that we hold about you will include the same information listed in paragraph 3.1 above and may include your CV, details of your previous employment history and professional activities, information relating to your financial status and dealings, nationality (including copies of identity documents, such as a passport), references provided by third parties and results of other due diligence carried out.
3.5 If you are an investor or potential investor, personal information we hold about you may include the same information as listed in paragraph 3.1, as well as bank account details, share in investments, amounts invested, returns from such investments and tax number, and information relating to your financial status and dealings, nationality (including copies of identity documents, such as a passport), references provided by third parties and results of other due diligence carried out. For more information relating to the information we hold about you if you are an investor, please refer to the relevant investment documentation.
3.6 We will take reasonable steps to keep the personal information that we store accurate and where necessary up to date. If you consider that any of the personal information that Mediterrania Capital Partners holds about you is incorrect please notify us, see Contact Information in paragraph 17 below.
4.1 The personal data will not be segmented or assigned to third parties or used for purposes other than the following:
4.2 We will not sell your personal information to others.
4.3 If we wish to use your personal information for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal information in accordance with the applicable law.
5.1 We may use your information to send you updates and news concerning Mediterrania Capital Partners and its business and activities and events which we feel may be of interest to you.
5.2 If at any time you wish us to stop using your information for these purposes, please notify Mediterrania Capital Partners, see Contact Information in paragraph 17 below.
6.1 In order to store, hold and process your data lawfully we rely on one or more of the following legal grounds:
7.1 There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:
8. Mediterrania Capital Partners is an international business and we may transfer your personal data to a third party in countries outside Malta including outside of the EEA for further processing in accordance with the purposes set out in this Privacy Policy. Your personal data may be transferred throughout the Mediterrania Capital Partners group and to our outsourced service providers located abroad, and this may include companies, offices or data centres. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisational, contractual or other lawful means. Please contact us if you would like more information about how your personal data may be transferred by Mediterrania Capital Partners and the safeguards that we have put in place; see Contact Information in paragraph 17 below.
9. We will take all reasonable steps to retain personal data only for the duration of the purpose for which it was obtained as set out in this Privacy Policy or when the consent is revoked (unless longer retention is required by the applicable law or regulation). We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
10.1 Mediterrania Capital Partners will take all reasonable steps to:
10.2 All our data is stored in written or electronic form on our servers and computers and in various physical locations. We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorised access or disclosure and loss or corruption by computer viruses and other sources of harm.
11.1 Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant data protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below at paragraphs 11.1.1 to 11.1.6:
11.2 Any request under paragraphs 11.1.1 to 11.1.5 should be submitted in writing to the Communications Manager at communications@mcapitalp.com. However, you do have the right to contact the relevant supervisory authority as noted in paragraph 11.1.6.
12. Our website may provide hyperlinks to websites owned and controlled by others. Mediterrania Capital Partners is not responsible and accepts no liability in relation to such websites or their contents or for their privacy practices. You should read any applicable privacy policy on any such website.
13. Where you submit personal information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their personal information, the reason you have provided it, how they can contact us and the terms of this Privacy Policy. You further confirm that they have consented to such collection, use and disclosure.
14.1 Mediterrania Capital Partners complies with the data protection and privacy laws to which it is subject. You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them. You should also be aware that privacy laws in various jurisdictions may change from time to time.
14.2 Except to the extent expressly stated otherwise in this Privacy Policy, Mediterrania Capital Partners accepts no obligations with respect to the handling of personal information other than those mandated by law in any relevant country.
15.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. This section of the Privacy Policy explains what cookies are, why we use them and what you may do if you wish to restrict, remove or refuse to accept cookies.
15.2 By continuing to use this website, you agree to the use of cookies for the purposes set out in this Privacy Policy.
15.3 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
15.4 We use the following cookies:
15.5 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Name | Purpose | Duration | More information |
| Google Analytics _ga | Used to distinguish users | 2 years | These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage |
| Google Analytics _gat | Used to throttle request rates to maintain website performance | 1 minute | |
| Google Analytics _gid | Used to distinguish users | 24 hours | |
| viewed_cookie_policy | Used to record if user has seen cookies message | 1 year | Used to record if user has seen cookies message |
| cookiesDirective | Used to record user preference in relation to cookies | 1 year | Used to record cookie acceptance and supress message after accepting cookie use. |
15.6 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
15.7 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
16. We reserve the right to change this Privacy Policy at any time and any changes will be posted here and you will be informed of it.
17. If you have any questions about this Privacy Policy, please contact us by email at communications@mcapitalp.com.
