We receive personal information from Data Subjects which includes:
Some of this information may be necessary in order for us to provide services to our clients and investors and to make investments on their behalf. With respect to providing services to our clients and investors, we will not be able to make an offer of interests in Funds, accept subscriptions of limited partners in Funds, enter into agreements with Separate Accounts, and facilitate transactions without obtaining your personal details and some information about your assets and investment experience, as well as having your account information. With respect to making investments in underlying funds and portfolio companies, we would not be able to conduct appropriate diligence and ongoing monitoring without obtaining personal information regarding the principals, other employees and representatives of the fund general partners and portfolio companies with which Adams Street Partners, LLC considers and/or undertakes investments.
We use the personal information held about Data Subjects for the following purposes:
The lawful basis/bases that we rely upon to process personal information held about Data Subjects is as follows:
We share personal data among our affiliates (including Adams Street Partners, LLC based in the USA) in order to carry out the purposes set out above.
We do not otherwise disclose any personal information about Data Subjects to any third parties, except:
In these cases, we may share personal information with legal advisers, accountants, service providers to Adams Street Partners and/or its Funds/Separate Accounts, companies engaged to dispose of or store data including personal information, and adverse parties who have a legal right to receive such information and their counsel, experts and legal advisers.
We will take reasonably necessary steps to ensure that where personal information is shared, it is treated securely and in accordance with this notice and applicable laws.
We will endeavour not to keep personal information in a form that allows a Data Subject to be identified for any longer than is reasonably necessary for achieving the permitted purposes. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymise personal information as part of such efforts. Once our relationship with the Data Subject has come to an end, we will retain the personal information for a period of time that enables us to maintain business records for analysis or audit purposes, comply with record retention requirements under applicable laws, defend or bring existing legal claims, and deal with any complaints about our services. We will delete the personal information when it is no longer required for these purposes, or if deletion is technically not possible, we will put in place measures to prevent that personal information from being used in any way.
We maintain physical, electronic and procedural safeguards designed to protect Data Subjects’ personal information, prevent unlawful or unauthorised processing of personal information, and prevent unauthorized disclosure of, or accidental loss of, or damage to, such information.
We restrict access to non-public personal information about Data Subjects to those of our employees and agents who need to know the information to enable us to provide services.
We may process personal information in, and transfer personal information to, countries that may not guarantee the same level of protection for personal information as the country in which Data Subjects reside.
Personal information will also be processed by staff that work for us and operate outside the European Economic Area. This includes staff engaged in, among other things, the provision of administration and support services. All such staff are subject to appropriate confidentiality and security obligations.
We will only transfer personal information to third party service providers if they agree to comply with the physical, electronic and procedural safeguards described above, or if they put in place adequate measures themselves.
Data Subjects have certain rights in relation to their personal information, including the right to be informed about the collection and use of their personal information, as outlined in this Policy.
These include, where certain conditions are met:
Data Subjects should use the contact information below to obtain more information and/or to make a formal request.
We will endeavour to keep the personal information we store about Data Subjects reasonably accurate and up-to-date by enabling clients and investors to correct it by request. Data Subjects should notify us if any of their personal information changes or if they become aware of any inaccuracies in the personal information we hold about them.