The new GDPR legislation requires Berggruen Holdings Limited, including any of its subsidiaries, affiliates, agents, employees or delegates, (all together, the “Company”) to provide this notice, which sets out how the Company will process personal information that it receives. Where your details are provided to the Company as a consequence of your engagement with it, we will process your personal information or, if applicable, that of your directors, officers, employees and/or beneficial owners. 

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‍PURPOSES OF PROCESSING AND LEGAL BASIS FOR PROCESSING 

Your personal data may be processed by the Company to comply with regulatory legislation for the following purposes:

1. In order to carry out anti-money laundering checks and related actions which the Company considers appropriate to comply with legal obligations imposed upon it;

2. To record electronic communications for the verification of instructions, investigations and fraud prevention purposes; crime detection prevention, investigation and prosecution; to enforce rights or defend the Company and its affiliates directly or through third parties to comply with any legal obligation imposed; and to pursue the Company’s legitimate interest in relation to such matters or where the processing is in the public interest;

3. To disclose information to other third parties such as service providers of the Company including regulatory authorities, payroll bureaus, technology providers, auditors and advisors in order to comply with any legal obligation imposed on the Company or to fulfil the services included in your engagement letter(s) with the Company; and

4. To update and maintain records.

THE COMPANY MAY DISCLOSE YOUR PERSONAL INFORMATION:

1. To its service providers and affiliates and other third-party service providers engaged by the Company in order to process the data for the above-mentioned purposes; and

2. To competent authorities (including tax authorities), courts and bodies as required by law or requested by any regulatory authority, where there is a legal obligation to report.

The disclosure of personal information to any third party may involve the transfer of data to jurisdictions outside the European Economic Area, in accordance with the requirements of GDPR. Such countries may not have the same data protection laws as the EEA. The Company has not verified the compliance of those third parties and cannot be held responsible if any party does not comply with GDPR.

RETENTION PERIOD 

The Company will retain your personal information for as long as required for it to perform services included within your engagement letter with the Company, or such longer period as may be required to fulfil its legal, professional and other obligations.

DATA SUBJECT RIGHTS

You have the following rights, in certain circumstances, in relation to your personal information:

1. The right to access your personal information;

2. The right to rectify your personal information;

3. The right to restrict the use of your personal information (in certain specific circumstances); and

4. The right to object to processing of your personal information (in certain specific circumstances).

You have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data relating to you, carried out by the Company, or its service providers, infringes the General Data Protection Regulation. 

HOW TO CONTACT BERGGRUEN HOLDINGS LIMITED

Should you have any questions about our use of your personal information, please contact Pipeline@berggruenholdings.com.

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