Privacy Policy

Last Updated May 2024

Antin Infrastructure Partners SAS (“Antin France”) and Antin Infrastructure Partners UK Limited (“Antin UK”) (“Antin”, “our”, “us”, or “we”) respect the privacy of every person who visits, registers with or submits personal data through the Antin website at antin-ip.com (the “Site”) and who uses the investment services that we offer, including from the Site (our “Services”) and we are committed to ensuring a safe online experience.

Purpose of this Notice

This privacy notice (“Privacy Notice”), which is supplemented by the EU and UK Privacy Notice and the California Privacy Notice, (each a “Jurisdiction-Specific Notice”), as applicable, explains our approach to how we use any personal data, personally identifiable information, personal information or other similar terms (your “personal data”) that we might collect from you or which we have obtained about you from a third party, including the nature of the personal data about you that is processed by us and the purposes for which we process your personal data. It also sets out rights you may have in respect of our processing of your personal data.

This Privacy Notice and the Jurisdiction-Specific Notices are intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.

Please also note that this Privacy Notice only applies to the use of your personal data obtained by us. It does not apply to your personal data collected during your communications with third parties or use of third-party websites.

If you have any questions, please get in touch with us via one of the methods set out in the “How to contact us” section.

Who does this Privacy Notice and the Jurisdiction-Specific Notices apply to?

This Privacy Notice, and the Jurisdiction-Specific Notices, apply to any natural person that we process personal data about where such personal data has been collected by us (or our service providers):

  • on or through our Site;
  • through offline and online communications (including emails and the “How to contact us” page on our Site);
  • when you visit our offices (including via our CCTV system); and
  • about representatives of our portfolio companies.

This Privacy Notice, and the Jurisdiction-Specific Notices, do not apply to any processing of personal data by or on behalf of us that is covered by a more specific privacy notice (including, but not limited to, our candidate and employee privacy notices).

In addition to reading this Privacy Notice, if you are:

  • a resident of California, please refer to our California Privacy Notice.
  • an individual located in the European Union (“EU”), the European Economic Area (“EEA”) or United Kingdom (“UK”), or if the processing of your personal data would otherwise be subject to EU and/or UK data protection laws, please refer to the EU and UK Privacy Notice.

What personal data do we collect and how do collect personal data?

Depending on the nature of our relationship or interactions with you we may collect some or all of the following kinds of personal data about you:

  • Your basic information: Name, prefix/title, gender, age and/or date of birth.
  • Contact information: Email address, physical address and/or phone number.
  • Information we obtain by automated means: Information about your computer or device, software and IP address.
  • Information obtained through communications with us: Information obtained through telephone calls (which may be recorded for regulatory purposes), video communications and other verbal communications, as well as written correspondence.
  • Images: Video footage or static images recorded by our CCTV cameras which are located at entrance and exit points to our offices, and/or photographs of you that are taken at our events (e.g., photographs of keynote speakers).
  • Other information: Information obtained through publicly available external websites (e.g., LinkedIn and other social media sites), and any other information relating to you that you may provide to us, including when you sign up to receive our news alerts and preferences or interests.

Please also refer to our [EU and UK Privacy Notice] and the [California Privacy Notice] for further information about what personal data we may collect.

We collect personal data that you voluntarily provide to us, such as through “Contact Us” forms you choose to submit on our Site to obtain more information about Antin or our funds. We may also collect personal data through the use of “cookies” on our Site, in the ordinary course of evaluating service providers, vendors and investments, in marketing our funds or from publicly available or accessible directories, databases and agencies. We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

In addition to personal data collected from your use of our Site, we may also collect personal data regarding our business contacts, partners, current and prospective investors, vendors and other contacts. We will collect some of this personal data if you contact our office or employees directly.

How do we use your personal data?

We may use your personal data for the following purposes:

Purpose Legal Basis (Relevant to EU and UK Privacy Notice)
To conduct business with you or to provide you with the Services, including responding to your enquiries and requests and providing you with support Contractual necessity; and/or our legitimate interest in operating our business and providing investment services
To communicate with you, to operate, schedule and facilitate meetings (in-person and online) and to administer your participation in any of our events Our legitimate interest in operating our business and providing investment services; and/or consent
To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a potential investor, business partner or supplier Our legitimate interest in operating our business and providing investment services; contractual necessity; legal requirement; and/or consent
To protect against, identify and prevent fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our Site, investor portals, products and services, databases, technology assets or our business, and other malicious, or unlawful activity Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely and safely
To conduct conflicts checks Legal requirement
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment which are evaluated by us or which we are party to Our legitimate interest in operating our business and providing investment services; contractual necessity; and/or legal requirement
To monitor and manage our portfolio companies Our legitimate interest in operating our business; and/or contractual necessity
To process and administer details associated with your investment and service your requests, and to offer and improve our services Our legitimate interest in operating our business; and/or consent
Complying with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you Legal requirement; our legitimate interest in operating our business; and/or consent
Litigation and dispute management and conducting internal audits and investigations Legal requirement; and/or our legitimate interest in operating our business
To enforce our agreement with you Our legitimate interest in operating our business; and/or contractual necessity
To keep a record of and manage your relationship with us Our legitimate interest in operating our business and providing services; and/or legal requirement
To obtain advice from our professional advisors, including lawyers and accountants Our legitimate interest in operating our business
To administer, market, and protect our business, and this Site Our legitimate interest in operating our business; and/or consent
To protect the rights, property or safety of us or third parties, including our other clients and users of the Site Our legitimate interest in operating our business; contractual necessity and/or legal requirement
To make suggestions and recommendations to you, or to provide you with updates or other information, about our business, funds, products and services that may be of interest to you Our legitimate interest in operating our business
For statistical analysis and market research, including to understand how our service may be improved for you (including through our use of cookies), and to improve our services Our legitimate interest in operating our business
For performance of IT systems Our legitimate interest in operating our business
For any other purposes that is required by law Legal requirement
For any other purpose that has been notified, or has been agreed, in writing Consent

Please note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.

No solely automated decision-making, including profiling, is used when processing your personal data.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Who do we share your personal data with?

We will only share your personal data with the following categories of third parties as permitted or required by law or regulation and to affiliates and service providers, including in the context of those third parties acting as data processors on our behalf and with whom we have a need to share such information to fulfil the purposes set out in this Privacy Notice and/or as necessary when providing the Services.

For the Fulfilment of our Services and business communication

We collect and maintain personal data that you voluntarily submit to us during your use of the Site and/or our Services to enable us to perform the Services. Please note that if you are a client of Antin, the contractual terms applicable to the particular Services you have subscribed to will also apply when we provide the Services.

Who we share your personal data with for this purpose:

  • Data storage companies who assist us in storing and backing up the data relating to our business. In particular, we use a third party data storage company which is located in Switzerland, outside EEA. For more information about our international data transfer practices, please see our EU and UK Privacy Notice as applicable;
  • Providers of software that we use in our business, including in relation to the production of investor notices and financial statements, client relationship management, investment management, reporting software and other software. For example, we use a third party supplier, Intralinks, Inc., to assist us with the hosting and management of our Investor Portal. Our third party provider is located in the United States. For more information about our international data transfer practices, please see our EU and UK Privacy Notice, as applicable ;
  • Fund administrators and other service providers who assist us with the performance of Services related to the Fund and meeting business operation needs (including the investment advisor, described below);
  • Web hosting and management companies who assist us with the hosting, operation and maintenance of our Site, the administration of your account with us and the provision of access to secure areas and functionality on our Site;
  • Banks who assist us by acting as depositories for client funds; and
  • Other entities within the Antin group of companies (notably, Antin UK or Antin France, as the context dictates), for the purposes described above, and the investment advisor, a member of the Antin group of companies which is registered and located in United States (“Antin US”) and provides us with investment advisory services. For more information about our international data transfer practices, please see our EU and UK Privacy Notice, as applicable.

For client services and enquiries

Our Site uses various user interfaces to allow you to request information about our Services and any accounts you may have with us. Our enquiry services are accessible by email and telephone. When making an enquiry, the enquirer’s name and contact information may be requested, together with details of other personal data that is relevant to the enquiry. This information is used in order to enable us to manage and respond to your enquiries and requests.

Who do we share your personal data with for this purpose?

  • We use a third party supplier, Intralinks, Inc., to assist us with client services. For more information about our international data transfer practices, please see our EU and UK Privacy Notice as applicable.
  • For the purposes described above, we also share personal data with other entities within the Antin group of companies (notably, Antin UK or Antin France, as the context dictates, and Antin Infrastructure Services (“Antin Luxembourg”), a member of the Antin group of companies which is registered and located in Luxembourg and assists us in relation to the handling of client enquiries and service requests).

For user insight and analysis

Subject to any consent requirements, we use cookies to collect personal data from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site.

Our web pages contain cookies. Cookies allow us to count users that have visited a web page and collect other types of aggregate information. Please see our Cookie Policy for further information.

This information is used to create insights about our users’ browsing habits on our Site. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors and clients like to see.

Who do we share your personal data with for these purposes?

We share your personal data with third party service providers to assist us with insight analytics. These providers are described in our Cookie Policy. For the purposes described above, we also share personal data with other entities within the Antin group of companies (notably, Antin UK or Antin France, as the context dictates). For more information about our international data transfer practices, please see our EU and UK Privacy Notice, as applicable.

For business administration and legal compliance

We use your personal data as necessary for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • to protect rights of third parties; and
  • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal data with for these purposes?

We will share your personal data with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities such as the UK’s Financial Conduct Authority (FCA) and France’s Autorité des Marchés Financiers (as applicable).

We also share personal data with other entities within the Antin group of companies for these purposes (notably, Antin UK or Antin France, as the context dictates).

For any other purposes as required

Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details and, where required by the law, we will obtain your consent before processing your personal data for those additional or different purposes.

We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

How do we obtain your consent?

Where our use of your personal data requires your consent, you can provide such consent:

  • at the time we collect your personal data following the instructions provided; or
  • by informing us by email, post or telephone using the contact details set out in the “How to contact us” section above.

Our use of cookies and similar technologies

Our Site uses certain cookies of which you should be aware. Please read our Cookie Policy to find out more about the cookies we use, the purposes for which we use them and how to manage and delete cookies.

Third party links and services

Our Site contains links to third party websites and services. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Notice applies solely to personal data collected by us through our Site and/or Services and does not apply to these third party websites and third party service providers.

How long do we keep your personal data?

Regarding personal data we have processed as part of providing the Services to any client, we will retain relevant personal data for at least six years from the date of our last interaction with that client and or for longer as we are required to do so according to law, our regulatory obligations or professional indemnity obligations. We may then destroy such files or anonymize them without further notice or liability.

Regarding any other personal data we process, we will retain relevant personal data for at least three years from the date of our last interaction with you or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations.

Confidentiality and security of your personal data

We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse, alteration, unauthorised access or disclosure.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, the data.

Unfortunately, no data transmission or storage system can be 100% secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data. Any transmission of personal data is at your own risk. Please keep this in mind when disclosing any personal data to us via the internet.

The safety and security of your personal data also depends on you. If you have an account with us, for example to secure areas of our Site, you are solely responsible for keeping your account details confidential, including any access credentials.

All our employees and data processors (i.e., those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site and our Services.

How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, submit any requests or appeal any of our decisions under this Privacy Notice, or request to view this Privacy Notice in an alternate format, please contact us by using the following details:

Write to us at:

  • 374 rue Saint-Honoré, 75001 Paris, France; or
  • 14 St. George Street, London W1S 1FE, U.K.

Send an email to contact@antin-ip.com.

Antin France is a société par actions simplifiée, incorporated under French law, having its registered office at 374 rue Saint-Honoré, 75001 Paris, France, registered with the Paris Trade and Companies Register (789 002 300). Antin France is authorised and regulated by the Autorité des Marchés Financiers (GP-15000003).

Antin UK is an English private limited company with registered company number 08492573, having its registered office at 14 St George Street, London W1S 1FE. Antin UK is authorised and regulated by the Financial Conduct Authority (FRN 649872). Antin UK is registered as a data controller with the UK Information Commissioner’s Office under registration number ZA161436.

Children

Our Site and Services are not directed to children, and we do not solicit nor knowingly collect personal data from children under the age of eighteen (18). If you believe that we have unknowingly collected any personal data from a child, please contact us.

Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time. In the event that we do so, an updated version of this Privacy Notice will be posted on the Site.

To ensure that you are always aware of how we use your personal data we will update this Privacy Notice from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.

EU and UK Privacy Notice

This EU and UK Privacy Notice supplements the Privacy Notice with respect to additional information as required by applicable EU and UK data protection laws, including Regulation (EU) 2016/679 (the “EU GDPR”), the UK equivalent of the EU GDPR (the “UK GDPR”) and the Data Protection Act 2018 (the “EU and UK Privacy Laws”). For the purposes of EU and UK Privacy Laws, we act as a controller of the personal data we collect in the ways described above (e.g., when you visit the Site).

What personal data do we process about you?

Our general Privacy Notice sets out what personal data we collect about you. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.) or any information about criminal convictions and offences.

What other legal bases do we rely upon?

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of failure to provide this personal data (e.g., inability to conduct business with you and cancelling an existing arrangement, receiving an unoptimized user experience when visiting our website, etc.).

International data transfers

If you are based within the EEA, the United Kingdom (“UK”) or Switzerland, please note that where necessary to deliver the Services and for the purposes specified in this Privacy Notice we may transfer personal data to entities (described above) located in countries outside those regions, to countries with laws governing data collection and use that may differ from the ones in your place of residence, notably to the United States. When doing so we will comply with our legal and regulatory obligations in relation to such transfers, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data (such as relying on an adequacy decision by the European Commission or the UK Government, for example where we transfer personal data to Switzerland, or by implementing the European Commission approved standard contractual clauses where we transfer data to the United States, unless an exception applies). Please contact us as set out under the “How to Contact Us” section above for more information on the safeguards we have in place for international data transfers.

What are your rights?

Under certain circumstances, by law you have the right to access personal data we maintain about you, and there are several ways you can control the way in which and what personal data we process about you. To exercise these rights, please let us know by using the details in the “How to Contact Us” section above.

  • Your right of access.
    • If you ask us, we’ll confirm whether we’re processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies or if your request for access is clearly unfounded or excessive, we may need to charge a reasonable fee. Alternatively, we may refuse to comply with the request in such circumstances.
  • Your right to rectification.
    • If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.
  • Your right to erasure.
    • You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
  • Your right to restrict processing.
    • You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances, such as where you contest the accuracy of that personal data or you object to us processing it. It won’t stop us from storing your personal data though. We will tell you before we lift any restriction. If we have shared your personal data with others, we will let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
  • Your right to data portability.
    • You have the right, in certain circumstances, to obtain personal data you have provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
  • Your right to object.
    • You can ask us to stop processing your personal data, and we will do so, if we are:
      • relying on our own or someone else’s legitimate interests to process your personal data (as described in this Privacy Notice), except if we can demonstrate compelling legal grounds for continuing processing you data; or
      • processing your personal data for direct marketing.

When we process your personal data based on a legitimate interest, we will not use that data for activities where the impact on you overrides your interests, rights and freedoms, unless we have consent or those activities are otherwise required or permitted to by law.

  • Your right to withdraw consent.
    • If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
  • Your right to lodge a complaint with the data protection authority.
    • If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, you can report it to the relevant regulator:

France:

Commission Nationale de l’Informatique et des Libertés (CNIL). You can find details about how to report a concern on the CNIL website at https://www.cnil.fr/en/home or by calling their helpline on +33 (0)1.53.73.22.22.

UK:

Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

Please contact us if you wish to exercise any of the rights set out above. In the event you do contact us, we may need to verify your identity to allow us to prevent disclosure of your information to an unauthorized person. The various rights are not absolute and each is subject to certain exceptions or qualifications. Where you are given the option to share your personal data with us, you can always choose not to do so. Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services. We normally respond to requests within one month. Occasionally it may take us longer, if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

We would appreciate the opportunity to deal with any concerns or questions you may have prior to you approaching the ICO or other relevant supervisory authority, so please contact us in the first instance at contact@antin-ip.com.

California Privacy Notice

This California Privacy Notice (the “California Privacy Notice”) supplements the Privacy Notice with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, and together with its implementing regulations and guidelines, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the [Privacy Notice]. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this California Privacy Notice apply to?

This California Privacy Notice applies to your interactions with us:

  • on or through our Site (as defined below);
  • through offline and online communications (including emails and the “How to contact us” page on our Site);
  • when you visit our offices (including via our CCTV system); and
  • about representatives of our portfolio companies.

What Categories of Information Do We Collect About You?

We collect limited types of personal information through the Antin website at antin-ip.com (the “Site”) and in connection with the investment services that we offer, including via the Site (our “Services”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Site over the last twelve (12) months include the following:

Category Examples Collected
A. Identifiers Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). YES
C. Protected classification characteristics under California or federal law Date of birth, citizenship and birthplace. NO
D. Commercial information Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). NO
E. Biometric information Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. NO
F. Internet or other similar network activity Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries. YES
G. Geolocation data Physical location or movements. NO
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO
I. Professional or employment-related information Current or past job history or performance evaluations. YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO
L. Sensitive Personal Information (see further information on use of sensitive personal information below) Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. NO

We do not knowingly collect or solicit personal information from anyone under the age of 18.

We do not collect or use sensitive personal information other than:

  • To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
  • As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
  • For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
  • To perform services on behalf of our business;
  • To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

We collect personal information for the business or commercial purposes and from the sources set forth in “How do we use your personal data?” and “What personal data do we collect and how do we collect personal data?”, respectively, in the Privacy Notice above. We retain the categories of personal information set forth above in “How do we collect personal data?” section of this California Privacy Notice only as long as is reasonably necessary for those purposes set forth in “How do we use your personal data?” in the Privacy Notice above, except as may be required under applicable law, court order or government regulations.

To Whom Do We Disclose Your Personal Information?

We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with this Site for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

We take measures to protect your personal information as set forth in “Confidentiality and security of your personal data” in the Privacy Notice above.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:

  • The categories of personal information we collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting such personal information;
  • Categories of third parties to whom we disclose the personal information;
  • The specific pieces of personal information we have collected about you; and
  • Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.

Email us at the following email address: contact@antin-ip.com.

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact contact@antin-ip.com with any questions about this California Privacy Notice.