Introduction

Arcus Infrastructure Partners LLP and all its affiliates (hereafter “Arcus”, “we”, “our”, “us”) are committed to protecting and respecting your privacy.  This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be used by us. It also describes the choices available to you regarding our use of your personal data and how you can access and update this information.

Please read the following carefully to understand how we will treat your personal data.

We keep our Privacy Policy under regular review to ensure it is relevant and up-to-date, and therefore reserve the right to amend it at any time, without notice, by placing a revised version on our Website. Your continued access to, or use of, the Website will mean that you agree to any changes from time to time.

This Privacy Policy was last updated in December 2024.

Who we are:

The Arcus group, including Arcus Infrastructure Partners LLP, the regulated entities, Arcus European Investment Manager LLP and Arcus European Investment Manager Netherlands B.V., and all their affiliates, is an independent infrastructure fund manager focused on digital, transport, logistics & industrials, and energy, exclusively in the European market.

Arcus European Investment Manager LLP

6th Floor, 1 Aldermanbury Square

London EC2V 7HR

United Kingdom

Arcus European Investment Manager Netherlands B.V.

De Lairessestraat 107-D (2nd Floor)

1071 NX Amsterdam

Netherlands

If you wish to contact us about anything in this Privacy Policy, please email our Data Protection Officer at DPO@arcusip.com.

What information we collect, use and why:

We may collect, record and use information about you in electronic form. We will hold, use and otherwise process it in accordance with the Data Protection Legislation (as defined below) in order to:

• run and maintain our Website;
• engage with you in connection with the provision or receipt of services, recruitment processes or in the process of proving your identity under our Know Your Customer (KYC) processes;
• enter into a contract or a subscription deed with us;
• contact us by phone, email or other means.

We may collect the following personal data from you:

• Contact information such as name, email address, mailing address, phone number, identification documents, client account information;
• Information about your business role, such as job title and company name;
• Information about your interests in our services and products;
• For the purpose of recruitment process, we collect contact details, date of birth, identification document, education history, employment history, right to work information, details of any criminal convictions (e.g. Disclosure Barring Service (DBS));
• Financial Information consisting of bank account details and tax status information.
• Details of your visits to this Website and the materials and information that you access.
• KYC records, such as passport details, social security number, date and place of birth, source of wealth, rationale for use of corporate structures, relationships with public officials, criminal record.

Our Website may also passively collect your information when you visit our Website through the use of online tracking tools, such as device’s unique identifier.

We may use the personal data for our legitimate business interests, including:

• To fulfil contractual obligations we may have with you;
• To respond to queries and customer service requests or concerns;
• To administer and manage delivery of our services and products to you;
• To provide you with information by letter, SMS, telephone and/or email on information that you request from us, or we feel may be of interest to you, where you have consented to be contacted for such purposes;
• To confirm your identity and carry out background checks in order to complete our KYC process, including as part of our checks in relation to anti-money laundering, compliance screening and to prevent fraud and other crimes;
• For research purposes;
• To notify you about changes to our services;
• To improve our Website and marketing efforts;
• To comply with any requirements of applicable law or regulations, and
• To manage conflicts of interest.

Lawful base and data protection rights:

Under UK Data Protection Law and the European General Data Protection Regulation (GDPR) (together, the “Data Protection Legislation”), we must have a “lawful basis” for collecting and using your personal information. We rely on one or more of the following lawful grounds:

• Consent –you’ve agreed to us processing your information for a specific reason or purpose;
• Contract – the processing is necessary for us to take steps to enter into an agreement with you;
• Legal obligation – the processing is necessary in order for us to comply with a legal or regulatory obligation to which we are subject;
• Legitimate interest – the processing is necessary for the purpose of a legitimate purpose pursued by us, including to keep you informed about products, developments or services that may be relevant to you, to protect our business interest, to ensure that our internal processes are well-managed, to prevent fraud or to evaluate, develop or improve our services.

At any time, you have the following rights in relation to your personal data:

• Your right of access – you have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for;
• Your right to rectification – you have the right to ask us to correct or delete personal information you think is inaccurate or incomplete;
• Your right to erasure – you have the right to ask us to delete your personal information;
• Your right to restriction of processing – you have the right to ask us to limit how we can use your personal information;
• Your right to object to processing – you have the right to object to the processing of your personal data;
• Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation, or to you;
• Your right to withdraw consent – when we use consent as our lawful basis, you have the right to withdraw your consent at any time.

We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.

Please contact us by email at DPO@arcusip.com if you wish to progress any of your rights as detailed above.

Where we get personal information from:

We may collect or obtain such information because you give it to us, or because third parties, such as business partners, suppliers, service providers, group companies, public Websites and/or background checking companies give that information to us on your behalf. Information could also be found with Regulatory authorities or on other publicly available sources.

How long we keep information:

We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations, or where longer, such longer period as is required by law or regulatory obligations which apply to us.

We will generally retain information about you throughout the life cycle of any investment you are involved in; some personal information will be retained after your relationship with us ends.

As a general principle, we do not retain your personal data for longer than we need it.

We will usually delete your personal information (at the latest) 7 years after your relationship with us has ended; this is due to fulfilling regulatory requirements.

Who we share information with:

Any information you provide will be controlled by Arcus. We will ensure that all information that you provide to us is treated in confidence and in accordance with our obligations under the Data Protection Legislation. We will not disclose such information to any third parties except (a) where required or permitted by law; or (b) where your consent has been received. Your details will not be given to third parties for marketing purposes.

We may disclose your personal data to other Arcus affiliates for the purposes stated above. Where we do so we will always use every reasonable effort to ensure your personal data is safeguarded to the same standards to which we are subject. We may also disclose your personal data to agents and service providers (within and outside the European Economic Area) of Arcus for such purposes, or if we or any affiliates are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply these terms and conditions or other agreements that may be in place with you, or to protect the rights of Arcus or its clients.  We will not sell your personal data to third parties for them to market their services to you.

Your personal data may also be shared (where relevant) with:

• Fund and managed accounts associates: the fund and managed accounts parties may share your personal data with associates, related parties and members of their group. This is to manage our relationship with you;
• Fund and managed account managers, depositaries, administrators and investment advisors: to enable us to deliver the services you require, support and administer investment related activities and comply with applicable laws and regulations;
• Tax authorities: to comply with applicable laws and regulations, where we are required to by EEA tax authorities (who, in turn, may share your personal data with foreign tax authorities) and where required by foreign tax authorities, including outside of the EEA;
• Service providers: to deliver the services you require and to comply with applicable legal and regulatory requirements, and
• In exceptional circumstances we will share your personal data with competent regulatory, prosecuting and other governmental agencies or litigation counterparties, in any country or territory and organisations and agencies when we are required to do so by law.

How to complain:

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy policy.

If you remain unhappy with how we have used your data after raising a complaint with us, you can also lodge a complaint about our processing of your personal data with the body regulating data protection in your country. A list of the EU data protection authorities is available by clicking this link http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

You can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place, either in the United Kingdom to ICO Information Commissioner’s Office (ICO) or in the Netherlands to AP https://autoriteitpersoonsgegevens.nl/.

Website, cookies and security:

We work with third parties to research certain usage and activities on our Website on our behalf. No personal information about you is shared with these third parties in the course of conducting this research.  The third parties may place a unique ‘cookie’ on your browser.

We also use ‘cookies’, which are small amounts of information stored on your computer’s hard drive that allow us to recognise your computer when you visit the site. Most browsers can be configured so as not to accept cookies, however in some cases this may affect the functionality of the Website. We set out more information on cookies in our ‘Cookies Policy’ on our Website.

Our Website may contain electronic images, known as web beacons or spotlight tags. These enable us to count users who have visited certain pages on the Website. Web beacons and spotlight tags are simply tools used to obtain generic information about the web pages visited. They are not used to obtain information about specific users.

The security of your personal data is important to us. We follow industry standards to protect the personal data submitted to us, both during transmission and once we receive it. No method of transmission over the internet, or method of electronic storage is 100% secure, however. Therefore, we cannot guarantee its absolute security.

By using the Website, you consent to us using your personal data in accordance with this policy and you confirm that all data provided by you is accurate.