Controller’s Contact details
Name: NGP Management Oy
Company ID: 2130715-9
E-mail address: firstname.lastname@example.org
Personal Data Processed and Sources of Data
The personal data collected and processed by us can be divided into two general data categories: (i) Contact Data; and (ii) Analytics Data. Although we do not normally use Analytics Data to identify individuals, sometimes individuals can be recognized from it.
NGP Capital may collect and process the following Contact Data: (i) name and contact details; (ii) organisation and title (iii) phone number; (iv) e-mail address; (v) correspondence; (vi) marketing opt-outs and opt-ins.
Most of the Contact Data is received directly from Contacts. In addition, personal information may be collected and updated from public registers and third parties for the purposes set out herein.
Analytics Data we gather in connection with the use of our Websites include for example the following data: (i) IP address; (ii) device and device identification number; (iii) operating system; (iv) time of visit; (v) browser type and version; (vi) language setting.
Please note that we use the online advertising product Twitter Tailored Audiences (Twitter Inc. 1601 S. San Francisco, California) to target you with advertising relating to our services and products. It is possible to opt-out of such targeted advertising through your Twitter profile settings.
The Websites offer newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
When you submit data through a form such as those found on contact pages or comment forms cookies may be set to remember your details for future correspondence.
Web analytics services
Our Websites use Google Analytics and other web analytics services to compile Analytics Data and reports on visitor usage and to help us improve the Websites. For an overview of Google Analytics, please visit Google Analytics. It is possible to opt-out of Google Analytics with the following browser add-on tool: Google Analytics opt-out add-on.
Purposes and legitimate grounds for processing of personal data
Personal data is processed by NGP Capital for the following purposes:
To provide our Websites and carry out our contractual obligations
We process personal data to be able to offer the Websites and to run, maintain and develop our business and to comply with our commitments to our Contacts and their organisations. Personal data may be processed in order to carry out our contractual obligations.
For communication, marketing and newsletters
We may process personal data for the purpose of contacting Contacts as well as to market our business and send newsletters.
For quality improvement
We may process information regarding the use of the Websites and our services and to improve the quality of our Websites and business.
Legitimate grounds for processing
We process personal data to perform our contractual obligations and to comply with legal obligations. Furthermore, we process personal data to pursue our legitimate interest to run, maintain and develop our business and to create and maintain business relationships. When choosing to use your data on the basis of our legitimate interests, we weigh our own interests against your right to privacy and e.g. provide you with opt-out mechanisms from our marketing communications.
You may be requested to grant your consent for the processing of personal data. In this event, you may withdraw your consent at any time.
Transfer to countries outside europe
NGP Capital stores the personal data primarily within the European Economic Area. However, we have service providers in several geographical locations. As such, we and our service providers may transfer personal data to, or access it in, jurisdictions outside the European Economic Area.
We will take steps to ensure that the personal data receives an adequate level of protection in the jurisdictions in which it is processed. We provide adequate protection for the transfers of personal data to countries outside of the European Economic Area through a series of agreements with our service providers based on the Standard Contractual Clauses or through other appropriate safeguards, such as the Privacy Shield Framework.
PERSONAL DATA recipients
We do not share personal data with third parties outside of NGP Capital’s organization unless one of the following circumstances applies:
For legal reasons
We may share personal data with third parties outside NGP Capital’s organization if we believe that access to and use of the personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of NGP Capital, our Contacts or the public in accordance with the law. When possible, we will inform Contacts about such transfer and processing.
For other legitimate reasons
If NGP Capital is involved in a merger, acquisition or asset sale, we may transfer personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data.
With explicit consent
We may share personal data with third parties outside NGP Capital’s organization when we have your explicit consent to do so.
We will store personal data for no longer than is required by law or reasonably necessary for our contractual obligations and legitimate interests for example for claims handling, internal reporting, marketing and accounting purposes.
We will store Analytics Data relating to the Websites for 26 months.
Right to access
You have the right to access your personal data processed by us and to request a copy of your personal data.
Right to withdraw consent
In case the processing is based on a consent, you may withdraw the consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Right to rectify
You have the right to have incorrect or incomplete personal data we have stored about you corrected or completed.
Right to erasure
You may also ask us to erase your personal data from our systems. We will comply with such request unless we have a legitimate ground to not delete the data.
Right to object
You may object to the processing of personal data on grounds relating to your particular situation if such data are processed for other purposes than purposes necessary for the performance of a contract or for compliance with a legal obligation. In case we do not have legitimate grounds to continue processing such personal data, we shall no longer process the personal data.
Right to restriction of processing
You may request us to restrict processing of your personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data.
Right to data portability
You have the right to receive some of your personal data that you have provided to us in a structured and commonly used format.
How to use the rights
The above mentioned rights may be used by sending a letter or an e-mail to us on the addresses set out above. We may request the provision of additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.
You have the right to prohibit us from using your personal data for direct marketing purposes, market research and profiling made for direct marketing purposes by contacting us on the addresses indicated above or by using the unsubscribe possibility offered in connection with any direct marketing messages.
Lodging a complaint
In case you consider our processing of personal data to be inconsistent with the applicable data protection laws, a complaint may be lodged with the local supervisory authority for data protection.
We use administrative, organizational, technical, and physical safeguards to protect the personal data we collect and process. Measures include for example, where appropriate, firewalls, secure facilities and access right systems. Should despite of the security measures, a security breach occur that is likely to have negative effects to the privacy of Contacts, we will inform the relevant Contacts as well as relevant authorities about the breach as soon as possible.