Data Protection and Privacy

General Terms

This data protection statement explains how Saratoga Capital Management Ltd. processes personal data in accordance with the EU General Data Protection Regulation (“GDPR”) and other applicable national data protection laws (collectively, referred to as “Data Protection Legislation”).

“Personal Data” means all details related to a specific or identifiable natural or legal person. “Processing” means all ways of dealing with personal data, irrespective of the means and procedures used, in particular procuring, storing, using, revising, disclosing, archiving and destroying of personal data.

This statement may be updated from time-to-time. We therefore ask you to consult it on a regular basis. The last line below indicates when the statement was last updated.

Who’s Personal Data do we process?

We process Personal Data from the following:

  • Professional and well-informed investors and/or other eligible investors who are based in the European Economic Area (EEA) or outside the EEA to whom Saratoga Capital Management Ltd. offers services, including but not limited to individuals who have invested in the funds that we manage.
  • Individuals connected to investors, such as the beneficial owner of the investment, persons that own, directly or indirectly, an interest in the investment, authorized signatories, authorized representatives, agents, employees.
  • Individuals connected or relevant to non-individual investors, such as companies, other corporate clients or other legal on non-legal entities to whom Saratoga Capital Management Ltd. services, including entities that are considering investing in the funds under management. Such persons may include, shareholders, owners, employees, directors, officers, authorized representatives or agents (e.g., external legal counsel or external auditors) and other associates.
  • Other individuals (e.g., staff candidates) that may be in any way connected with the work that Saratoga Capital Management Ltd. is engaged to provide to its investors.
  • Employees and other persons working for Saratoga Capital Management Ltd., including persons applying to us for employment.
  • Our associates (which may include without limitation, our service providers and other third parties, such as IT service providers, auditors, consultants, background check providers with whom we may cooperate in offering our services to our Investors.
  • Visitors to our Website.

What personal data do we process?

We process various types of personal data related to you, subject to Data Protection Legislation, as follows:

  • Personal details such as name, surname, place and date of birth, residential address, email address, telephone number, ID, passport, signature as well as other such data.
  • Due diligence and know-your-customer information and documentation that we are legally obliged to collect that includes, but not limited to, a passport or other personal identification information, proof of address information, nationality, place and date of birth, country of residence, job, source of wealth, tax reference and background information such as non-bankruptcy records and clean criminal records.
  • Information relating to professional relationships – this includes, but not limited to, your financial or other transactions, business dealings, tax information, marital status, history.
  • Financial details such as a bank account, credit card details, bank policies, loan agreements, credit facilities, tax reference, billing information, payment details.
  • Employment and professional details such as an employment contract, curriculum vitae, academic qualifications, diplomas, references, certificates, information relating to your professional and academic qualifications, work experience, references and other information, social media information, where you may apply to us for employment or for consideration in recruitment services that we might engage.
  • Any other personal data that may be provided to us by you or third parties.

Right to lodge a complaint

If you have any concern about any aspect of our data protection and privacy policy or want to file a complaint and/or want us to provide you with any information regarding the processing of your personal data by Saratoga Capital Management Ltd., you may contact us via email at GDPR@saratogacap-mgt.com. 

This policy was last updated on 01.07.2024.