Privacy Policy

Last updated: February 2025

ZMC ADVISORS, L.P. WEBSITE PRIVACY POLICY

Privacy Policy

ZMC Advisors, L.P. and its affiliates (“ZMC”, “we” or “us”) are committed to protecting the privacy of our website visitors. This privacy policy, together with the California Website Privacy Policy and the EEA-UK Website Privacy Policy Notice supplements (the “Privacy Policy”) provides information explaining whether and how we collect information about you when you visit our website or other websites we control and where this Privacy Policy is posted (the “Site”), and how we use such information. The Privacy Policy describes the manner in which we process your personal information and the measures we take to preserve the privacy and security of your personal information. For simplicity, we use the terms “personal information”, “personally identifiable information” and “personal data” in this Privacy Policy (and any additional jurisdiction-specific privacy notices) interchangeably. This Privacy Policy does not address our privacy practices concerning any personal information we collect as to our investors; we address those practices in separate notices sent to our investors or potential investors or make available within our LP portal.

This Privacy Policy constitutes a legally binding agreement between ZMC and you, the user of this Site. By entering and using this Site, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy for any reason, please do not use this Site or share your personally identifiable information (defined below) with us as discussed below.

The information presented on or through the Site is made available for informational purposes only and should not be construed as investment advice. The information presented does not, and shall not be deemed to constitute an offer to sell, or a solicitation to any person to buy, any security or other investment. Any such offer or solicitation may only be made pursuant to relevant final private placement memorandum, subscription agreement and other related documents with respect to a particular investment opportunity and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor.

This Privacy Policy complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under state or non-U.S. laws that may apply to you, including as set forth in our additional jurisdiction-specific privacy notices.

Visitors that are residents of California should also refer to our California Website Privacy Policy.

If you are located in the United Kingdom (the “UK”), the European Union (the “EU”) or the European Economic Area (the “EEA”), or the processing of your personal data would otherwise be subject to the EEA-UK Data Protection Laws (defined within the supplement), please also refer to our EEA-UK Privacy Policy supplement.

Our Site may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest that you review. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of those websites.

The Information We Collect

We collect limited types of personal information through our Site. The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Site over the last twelve (12) months include the following:

  • Your basic information: such as your name, prefix/title, gender, age and/or date of birth.
  • Contact information: such as physical address, telephone number and/or email address.
  • Information we obtain by automated means: such as information about your computer / device and IP address, content and traffic data. We may also collect personal data about you through automated technology when you access and use our Site, such as cookies and similar technology (please see the “Cookies” section below for information about how we use such technologies).
  • Information obtained through communications with us: such as information obtained through telephone calls (which may be recorded for compliance purposes), video communications and other verbal communications, and written correspondence.
  • Other information: such as information provided by third parties or obtained through publicly available sources.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

ZMC does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. To learn how to set your preferences so that websites do not track you, consult the help pages of your browser.

How We Obtain Your Personal Information

In connection with forming and operating our Site, we may collect and maintain your personal information from the following sources:

  • Information from your communications with us in connection with this Site, including any update notices provided by you.
  • Information captured on our Site, including registration and account information, information provided through online forms, the “Contact Us” page and any information captured via cookies.

We may also collect and maintain your personal information from the following sources:

  • information obtained through communications with us, such as information obtained through telephone calls (which may be recorded for regulatory purposes), video communications and other verbal communications, as well as written correspondence, including when you provide it to us in online correspondence via email; and/or
  • information obtained through the conduct of our business, such as information about you from the forms and any associated documentation that you complete when subscribing for an investment, shares and/or opening an account with us, including KYC and anti-money laundering information.

How We Use the Information We Collect

We will use the personal information we collect for one or more of the following business or commercial purposes:

Purpose Legal Basis (relevant to the EEA-UK Website Privacy Policy supplement)
To conduct business with you or to provide you with the services or information you have requested, including responding to your inquiries and requests and providing you with support. Contractual necessity; and/or our legitimate interest in operating our business and providing investment services.
To communicate with you, to operate, schedule and facilitate meetings (in-person and online) and to administer your participation in any of our events. Our legitimate interest in operating our business and providing investment services; and/or consent.
To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a potential investor, business partner or supplier. Our legitimate interest in operating our business and providing investment services; contractual necessity; legal requirement; and/or consent.
To protect against, identify and prevent fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our Site, investor portals, products and services, databases, technology assets or our business, and other malicious, or unlawful activity. Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely and safely.
To conduct conflicts checks. Legal requirement.
To process and administer details associated with your investment and service your requests, and to offer and improve our services. Our legitimate interest in operating our business; and/or consent.
Complying with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you. Legal requirement; our legitimate interest in operating our business; and/or consent.
Litigation management and conducting internal audits and investigations. Legal requirement; and/or our legitimate interest in operating our business.
To keep a record of and manage your relationship with us. Our legitimate interest in operating our business and providing services; and/or legal requirement.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Site users is among the assets transferred. Our legitimate interest in operating our business.
For any other purpose that has been notified in writing. Consent.

We may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information.

Additionally, we may use your personal information to keep you informed of our services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about services similar to those which we provide you, in which you may be interested. You may opt-in or opt-out to certain kinds of marketing, or all forms of marketing at any time, by contacting us.

Disclosure of Your Information and Retention

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within ZMC may be given, or given access to, your personal information. We may also use or disclose this information for our commercial or business purposes. We may associate your personal information with other information we collect about you but we will not sell this information or disclose it to third parties except as otherwise described in this Privacy Policy. For the avoidance of doubt, affiliate companies of ZMC (including portfolio companies) have different policies and administer them independently of ZMC itself.

To the extent you provide us with any personal information through or in connection with this Site, you acknowledge and agree that we may use or disclose personal information for any of the business or commercial purposes described in this Privacy Policy.

We may disclose personal information under any of the following limited circumstances:

  • When we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request, or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts and privacy) or may expose us to criminal or civil liability;
  • To enforce our Privacy Policy;
  • To protect your safety or security, including the safety and security of property that belongs to you;
  • To protect the safety and security of our websites (including the Site), databases, or the tangible or intangible property that belongs to us or to third parties;
  • To our affiliates;
  • As appropriate, our service providers, including, for example, (i) fund managers, depositories, administrators, placement agents, custodians, investment advisors and other fund administrators; (ii) recruitment firms, consultants IT and data security providers and/or data hosting providers; and (iii) our lawyers, auditors and other professional advisors; and
  • If ZMC merges with or transfers substantially all of its business, stocks or assets to another entity, ZMC has the right to share your personal information with that entity, to the extent lawfully permissible; provided that if such merger or transfer results in a material change in the use of your personal information, we will use commercially reasonable efforts (as determined by ZMC) to provide you with notice of such event and we will request that the new entity follow the practices disclosed in this Privacy Policy or notify you of any changes to it.

We review the personal data we hold periodically and delete it securely. We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact compliance@zmclp.com.

Please note that this Privacy Policy applies only to the Site, and not to any other affiliate or third-party website that may be linked to it or by it. ZMC does not endorse, have any responsibility for, or make any representations about, any other affiliate or third-party websites, including their products, services, content, communications or website use policies, and ZMC disclaims any responsibility for your access and/or use thereof. We do not control the privacy policies or practices of others.

Cookies

Information regarding how you access this Site (e.g., browser type, access times and IP address) and your hardware and software may automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information may be used to improve website performance and for our business purposes, including to help provide you with a better experience when you browse the Site.

Security

The security of your personal information is important to us. We employ robust and appropriate security measures to protect any personal information you provide through the Site from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your information.

Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.

We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Privacy Policy Changes

We will revise or supplement this Privacy Policy from time to time. If we make any substantial changes in the way we use or share your personal information, we will notify our web site visitors by posting a prominent notice in the Privacy Policy section of our website. Because other changes may not be so announced, we urge you to review this Privacy Policy each time you visit the Site so that you understand our current privacy policy. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will update this policy by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued use of and visitation to the Site constitutes your acceptance, acknowledgement and understanding of this Privacy Policy.

Capacity

This Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this Site who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

Governing Law/Forum

Subject to the EEA-UK Data Protection Legislation (as defined in the EEA-UK Website Privacy Policy supplement), this Privacy Policy is governed by the laws of the State of New York. In the event of any dispute relating to this Privacy Policy or your use of the Site, you agree that, subject to the EEA-UK Data Protection Legislation it shall be resolved solely in the state or federal courts located in New York County, New York or the United States District Court for the Southern District of New York located in New York County, New York. You agree to waive trial by jury in any such action.

Nothing contained in this Privacy Policy is intended to modify or amend any other written agreement you may have with ZMC, if any, that may currently be in effect. In the event any inconsistency between this Privacy Policy and any other agreements with ZMC, the other agreements with ZMC will govern.

Contact Us

If you have any questions or comments about this Privacy Policy, wish to access this Privacy Policy in an alternative format, submit requests, or wish to notify us of any errors or changes as to any personal information you provide us through this Site (each, a “Communication”), you can e-mail us at compliance@zmclp.com or write to us at ZMC, Attn: Privacy Matters, 110 East 59th Street, 24th Floor, New York, NY 10022, (212) 223-1383.

We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.

California Website Privacy Policy

Last Updated: February 2025

This California Website Privacy Policy (the “California Privacy Policy”) supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this California Privacy Policy apply to?

This California Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to us through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails or social media messaging), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:

Category Examples Collected
A. Identifiers Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). YES
C. Protected classification characteristics under California or federal law Date of birth, citizenship and birthplace. NO
D. Commercial information Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). NO
E. Biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. NO
F. Internet or other similar network activity Use of our Site, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries. YES
G. Geolocation data Physical location or movements. NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below) Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. NO

We do not collect or use sensitive personal information other than:

  • To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
  • As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
  • For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
  • To perform services on behalf of our business; and
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

How do we use your personal information?

We collect personal information for the business or commercial purposes and from the sources set forth in “The Information We Collect” and “How We Obtain Your Personal Information,” respectively, in the Privacy Policy above. We retain the categories of personal information set forth above in the “What information do we collect about you?” section of this California Privacy Policy only as long as is reasonably necessary for those business or commercial purposes set forth in “The Information We Collect” in the Privacy Policy above, except as may be required under applicable law, court order or government regulations.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

To whom do we disclose your personal information?

We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business or commercial purpose to the categories of third parties indicated in the chart below, and to affiliates and service providers, including, but not limited to, administrators, lenders, banks, auditors, law firms, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants, third-party due diligence providers and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category Category of Third-Party Recipients
A. Identifiers Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law N/A
D. Commercial information N/A
E. Biometric information N/A
F. Internet or other similar network activity Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.
G. Geolocation data N/A
H. Sensory data N/A
I. Professional or employment-related information N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) N/A
K. Inferences drawn from other personal information N/A
L. Sensitive Personal Information Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

How do we keep your personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

  • Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
  • Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
    • the categories of personal information we collected about you;
    • the categories of sources from which the personal information is collected;
    • our business or commercial purpose for collecting such personal information;
    • the categories of third parties to whom we disclose the personal information;
    • the specific pieces of personal information we have collected about you; and
    • whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
  • Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
  • No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
  • How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, to access this notice in an alternative format, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the following methods below:

  • If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at the address below, and we will call you during normal business hours.
  • Email us at the following email address: compliance@zmclp.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Please contact us at compliance@zmclp.com with any questions about this California Privacy Policy.

EEA-UK Website Privacy Policy supplement

This EEA-UK website privacy policy supplement (the “EEA-UK Website Privacy Policy”) describes how we process and use personal information from visitors of the Site in accordance with the EU General Data Protection Regulation (“EU GDPR”), the Data Protection Act 2018, and any other laws applicable in the EU and/or the UK concerning the protection and/or processing of personal data (together, “EEA-UK Data Protection Legislation”).

You do not need to take any action as a result of this EEA-UK Website Privacy Policy, but you may have certain rights as described below in the section headed “Your Rights”.

Information required to be disclosed under EEA-UK Data Protection Legislation regarding the collection of your personal data that is not set forth in this EEA-UK Website Privacy Policy is otherwise set forth in the Privacy Policy. To the extent there is any conflict in respect of any processing subject to EEA-UK Data Protection Legislation between the general Privacy Policy and this EEA-UK Website Privacy Policy, this EEA-UK Website Privacy Policy shall apply. Please read this EEA-UK Website Privacy Policy carefully.

For the purposes of EEA-UK Data Protection Legislation, ZMC and its private investment funds, their respective general partners, and their respective affiliates will each be a controller of any personal data collected by us. In simple terms, this means that we: (i) “control” the personal information data that we collect from you or other sources provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data. If you have any questions regarding our use of your personal data, or this EEA-UK Website Privacy Policy, please email us at compliance@zmclp.com.

Any Additional Personal Data We May Collect

As discussed in the “The Personal Information We May Collect” section of the Privacy Policy, the types of personal data we collect about you depends on the product or service you have requested from us and/or the nature of your interaction with us.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), although there may be limited circumstances where we need to collect this type of personal data, or it is collected incidentally. Nor do we collect any information about criminal convictions and offences.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we may not be able to provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How We Obtain Your Personal Data

In connection with the forming and operating the Site, we collect and process your personal data from you and other third parties and/or publicly available sources listed in “How We Collect Your Personal Information” section of the Privacy Policy above.

How We Use Your Personal Data

Further information about the legal bases under which we process your personal data is included in the section of the Privacy Policy headed “How We Use Your Personal Information.”

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

No automated decision making, including profiling, is used when processing your personal data.

Disclosure and Transfers of Personal Data

Your personal data will be shared with our affiliates and certain service providers as necessary to fulfil the purposes set out in the Privacy Policy, including professional advisors, recruitment firms, consultants and data hosting providers, as permitted by law or regulation, including the EEA-UK Data Protection Legislation.

To the extent your personal data is transferred to a Non-Equivalent Country (as defined below), such transfers will only be made in accordance with EEA-UK Data Protection Laws. For the purposes of this EEA-UK Website Privacy Policy, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK (as applicable) in accordance with the applicable EEA-UK Data Protection Laws to ensure an adequate level of protection for personal data. For further information about the safeguards/derogations used, please contact compliance@zmclp.com.

We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

Retention and Security of Personal Data

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so and your information is subject to the breach.

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EEA-UK Website Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact compliance@zmclp.com.

Your Rights

Under certain circumstances, by law you have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact compliance@zmclp.com.

  • Access: You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
  • Correction: You may notify us of changes to your personal data if the data we hold and process about you is inaccurate or it needs to be updated.
  • Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
  • Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data override your own rights.
  • Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
  • Portability: If you wish to transfer your personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
  • Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose not specified in this EEA-UK Website Privacy Policy, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Contact Us

If you have any questions or concerns about this EEA-UK Website Privacy Policy, please contact us by emailing us at compliance@zmclp.com.

Complaints

Should you wish to lodge a complaint with regards to how your personal data has been processed by us under:

  • the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
  • the EU GDPR, please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.

We would, however, appreciate the opportunity to address your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.