Privacy Policy

July 2024

MV Credit Partners LLP and MV Credit SarL incl. its branch in Paris (“MV Credit”, “we”, “our”), companies under common ownership and control, are both dedicated to protecting the confidentiality and privacy of information entrusted to them. As part of this fundamental obligation, we are committed to the appropriate protection and use of personal information (sometimes referred to as “personal information”, "personally identifiable information" or "PII") that has been collected online. Personal information means mean any information relating to an identifiable human being. An “identifiable” person is one who can be identified, directly or indirectly, for example, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to their physical, physiological, genetic, biometric, mental, economic, cultural, or social identity.

We will always comply with any applicable data protection legislation and we will ensure that collection and use of personal information is carried out in accordance with applicable data protection laws. The main laws governing data protection are, in France and Luxembourg, the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016) known as the “GDPR” and, in the United Kingdom, the GDPR, as it is now adopted into local law following Brexit, and the Data Protection Act 2018.

We comply with current requirements to notify our data processing activities to the UK Information Commissioner’s Office and are registered under number ZA120754.

Each MV Credit company is the controller of all personal information used within the relevant business for its own commercial purposes. Sometimes though, we will process personal information on behalf of another data controller – and when this is the case, we will do so only in accordance with the instructions of that data controller and otherwise in accordance with the law. If we are processing on behalf of another data controller, that data controller will provide relevant information to you about how your data is being shared.

Please review this privacy statement ("Privacy Statement") to learn more about how we collect, use, share and protect the personal information that we have obtained. Unless stated otherwise, you can presume that each of MV Credit Partners LLP and MV Credit SarL, depending on who you are dealing with, is using your personal information in the same ways.

Collection and use of personal information
Sharing and transfer of personal information
Choices
Access
Data security and integrity
Links to other sites
Changes to this statement
Policy questions and enforcement

1. Collection and use of personal information

1.1 What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal information to MV Credit companies (if, for example, you are a former employee). If you choose to register or login to one of our websites using a third party single sign−in service that authenticates your identity and/or connects your social media login information (e.g., LinkedIn, Google, or Vimeo), we will also collect any information or content needed for the registration or log−in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

We may also collect personal information about you from other sources, such as referrers, recruitment agencies, external providers we use to verify client data and other companies within the Natixis group of companies. Where we undertake legal and regulatory checks on clients, investors and related parties, we will also collect personal information regarding those controlling relevant entities from Companies House, the electoral roll and other public sources in the relevant jurisdiction.

By registering and/or submitting personal information to us, you are also acknowledging that MV Credit may use this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a MV Credit website and provide information about your preferences we will use this information to personalise your user experience. Where you register or login using a third party single user sign−in we may also recognise you as the same user across any different devices you use and personalise your user experience across other MV Credit sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with MV Credit, we will use the information that you provide to match you with available MV Credit job opportunities.

In some cases where you have registered for certain services, we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the address provided as part of your registration to confirm a subscription request).

1.2 The legal grounds we have to use your personal information

We generally collect only the personal information necessary to fulfill your request or to perform necessary actions. If you make available additional, optional information, it will also be used in accordance with this Privacy Statement.The law allows us to process personal information, so long as we have a “lawful basis” to do so - it also requires us to tell you what that basis is. As a result, when we process your personal information, we will rely on one of the following processing conditions:

Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract with you;
Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
Legitimate interests: we may process information about you where it is in our legitimate interest to do so in order to further that business, so long as it doesn’t outweigh your interests; or
Your consent: we may occasionally ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. We will only rely on consent that is freely-given, specific, informed and unambiguous. You may withdraw your consent at any time by contacting compliance@mvcredit.com.

We will only use your personal information for the purposes for which we collected it and/or it is provided by you unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal information without your knowledge or consent where required or permitted by law.

If you provide us with any personal information relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal information may be shared with us and to provide them with a copy of this Privacy Statement.

Purpose of processing	Types of data	Lawful basis
To provide you with information or services that you request from us	Contact details	Performance of a contract
To carry out our obligations arising from any contracts entered into between you and us	Contact details, banking or payment information and any information relating to personalised requirements	Performance of a contract
To conduct new client checks in order to verify your identity and/or source of funds	Contact details, banking or payment information, passport, driving licence, identification documents	Legal obligation
To ensure that content from our website is presented in the most effective manner for you and for your device	Online identifiers, location data and other technical information	Legitimate interest of presenting a user-friendly website
To allow you to participate in interactive features of our service, when you choose to do so	Online identifiers, location data and other technical information	Legitimate interest of presenting a user-friendly website
To provide you with information or services that we feel may interest you, for example by way of e-newsletter (where you have consented to be contacted for such purposes, to the extent consent is required by law)	Contact details and any information relating to personalisation preferences and transaction history	Legitimate interest in promoting relevant services and offers; consent
To notify you about changes to our service	Contact details	Legitimate interest of communicating service messages
To retain basic transaction details for the purpose of tax reporting	Contact details and transaction history	Legal obligation
To use non-essential cookies on our website (see “Cookies” section below for further information)	Online identifiers, location data and other technical information	Consent
To consider any application you may make via our website to work with MV Credit	Contact details, education and work history, recordings of any virtual interviews (and interviewer notes), copies of right to work documentation, references, other information you may choose to include in a job application	Legitimate interest of conducting a fair recruitment process. Performance of a contract.
To provide access to any Investor Portal and/or Data Rooms	Contact details	Performance of a contract; Legitimate interest of providing a user-friendly service.
To monitor, detect and prevent financial crimes	Email traffic and other electronic communications (including instant messages and phone calls) used as part of our services, name, email address, IP address.	Legal obligation

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to engage you as a client). In this case, we may have to cancel a service you have with us but we will notify you at the time if this is the case.

1.3 Sensitive personal information

We only collect "sensitive" or “special category” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual orientation or the processing of genetic or biometric data for the purpose of uniquely identifying someone; similar rules apply to information relating to criminal offences or related security measures. Please use your discretion when providing sensitive information to any MV Credit company, and do not provide it unless specifically needed. If you have any questions about whether the provision of sensitive information is, or may be, necessary or appropriate for particular purposes, please contact compliance@mvcredit.com.

We may process sensitive personal information about an individual in the following circumstances:

Where we have legal health and safety obligations, we will process information about an individual’s physical or mental health, or disability status, to ensure health and safety and to provide appropriate adjustments the individual might require to access our premises.
Where the individual has given explicit consent, we may use information about an individual’s race or national or ethnic origin, religious, philosophical, or moral beliefs, or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Where we are required by employment or immigration law to do so, we may collect and review job applicant information relating to nationality and right to work.
Where we have reasonable grounds to consider the prevention of unlawful acts is valid, we will request new recruits in certain roles agree to a DBS (Disclosure and Barring Service) check.
Where we are required to undertake Anti Money Laundering and Know Your Customer (KYC) checks to guard against unlawful acts or fraud, we will process passports and other identification documents that may disclose an individual’s nationality and belief.

1.4 Automatic collection of personal information

In some instances, MV Credit and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customise your online experience, improve the performance, usability, and effectiveness of our online presence, and to measure the effectiveness of our marketing activities.

1.4.1 IP addresses

An IP address is a number assigned to your computer or device whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct website trend and performance analysis.

1.4.2 Cookies

Cookies may be placed on your computer or internet−enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes. Please see our Cookie Policy for further information.

On our website, a notification banner may appear requesting your consent to set cookies. If you do not provide consent, some functions of our website may not operate.

1.5 Children

We understand the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

2. Sharing and transfer of personal information

2.1 Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:

Our service providers: we work with reputable partners, service providers or agencies so they can process your personal information on our behalf in order to provide support services, such as hosting our recruitment portal or other portals or other IT systems or providing outsourced administrative services. We will only transfer personal information to suppliers when they meet our strict standards on the processing of data and security and have agreed to certain contractual requirements. We only share personal information that allows these third parties to provide their services and do not authorise any other uses of your data.
Professional advisers: we may need to share certain personal information with professional advisers, such as lawyers, subject always to strict confidentiality obligations.
If we are reorganised or sold to another organisation: we may also disclose personal information in connection with the sale, assignment, or other transfer of part of our business;
Intra-group: both MV Credit companies may share data with each other, with our parent company, Natixis Investment Managers, and with our affiliates where they provide support services to us or for internal reporting and monitoring purposes.
Courts, tribunals, law enforcement or regulatory bodies: we may disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations, including bodies such as HMRC and financial services regulators.
Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat. Disclosure in such circumstances would be subject to confidentiality obligations so far as possible and limited to the disclosure strictly needed.

In addition, we may transfer certain personal information outside of the UK or EU to organisations working with us or on our behalf for the purposes described in this Privacy Statement. We may also store personal information outside of the UK or EU. If we do this your personal information will continue to be protected by suitable safeguards, usually by means of contracts we have in place with those organisations, which are in a form approved by the Information Commissioner’s Office or other local supervisory authority.

We will not transfer your personal information to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any personal information to us, but we may require you to provide certain personal information in order for you to receive additional information about our services and events. We may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt−in for particular services or communications, such as an e−newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

4. Your rights

If an MV Credit company is processing your personal information, you have the following rights:

Access − You can ask us to verify whether we are processing personal information about you, and if so, to provide more specific information.

Correction − You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.

Erasure − You can ask us to erase (delete) your personal information after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.

Processing restrictions − You can ask us to temporarily restrict our processing of your personal information if you contest the accuracy of your personal information, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.

Data portability − In some circumstances, where you have provided personal information to us, you can ask us to transmit that personal information (in a structured, commonly used, and machine−readable format) directly to another company if it is technically feasible.

Automated Individual Decision−making − You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you. We do not currently rely on automated decision-making processes.

Right to Object to Direct Marketing including Profiling − You can object to our use of your personal information for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.

Right to Withdraw Consent − You can withdraw your consent that you have previously given to one or more specified purposes to process your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.

You can make a request or exercise these rights by contacting compliance@mvcredit.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

You will not have to pay a fee to exercise any of these other rights, although we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive - alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity. We may also contact you to ask for further information in relation to your request to speed up our response.

5. Data security and integrity

We have security policies and procedures in place designed to protect personal information from unauthorised loss, misuse, alteration, or destruction. Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We have put in place internal procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

We retain personal information only for so long as the information is necessary for the purpose for which it was collected. We may sometimes anonymise your personal information (so that it can no longer identify you) for statistical purposes, in which case we may use this information indefinitely without further notice to you.

6. Links to other sites

Please be aware that our websites may contain links to other sites, including sites maintained by other Natixis affiliate firms, that are not governed by this Privacy Statement but by other privacy statements that may differ. We encourage users to review the privacy policy of each website visited before disclosing any personal information.

7. Changes to this statement

We may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how MV Credit is protecting your information.

8. Policy questions and enforcement

MV Credit is committed to protecting the privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at compliance@mvcredit.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

If you are not satisfied with the response you receive, you may escalate your concern to Compliance by sending an email to compliance@mvcredit.com. We will acknowledge your email within 14 days and seek to resolve your concern within three months or receipt. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds. In any event, you always have the right to lodge a complaint with the UK or LUX regulator in charge of protecting personal information, the Information Commissioner (www.ico.org.uk) or the Luxembourg National Commission for Data Protection (www.cnpd.public.lu).

MV Credit Partners LLP, 45 Old Bond Street, London W1S 4QT

MV Credit SarL, 51 Avenue JF Kennedy, L-1855 Luxembourg, Grand Duchy of Luxembourg

MV Credit SarL (Paris Branch), 5-7 rue de Monttessuy, 75007 Paris, France