Privacy Policy
Last Updated November 2021
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.
1 Purpose of this Policy
This privacy policy (“Privacy Policy”) explains our approach to any 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 your rights in respect of our processing of your personal data.
This Privacy Policy is 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 Policy 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.
2 Who are we and what do we do?
The Site and our Services are operated by Antin Infrastructure Partners SAS (“Antin France”) and Antin Infrastructure Partners UK Limited (“Antin UK”), whose principal activities include investing in infrastructure in Europe.
The data controller responsible for your personal data will depend on which country you access the Site from and which Antin entity you provide any personal data to or contract with in relation to the Services. For example, if you contract with Antin France, then Antin France will be the data controller. If you contract with Antin UK, then Antin UK will be the data controller.
References in this Privacy Policy to “Antin”, “we”, “us” or “our” are to Antin France and Antin UK as the context dictates.
Antin France is a société par actions simplifiée à capital variable, 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.
3 How to contact us?
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, 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.
4 What personal data do we collect and how do we use it?
Our primary goal in collecting personal data from you is to: (i) verify your identity; (ii) provide our Services to you; (iii) communicate with you, send you information about our products and services, and other news (iv) carry out requests made by you on the Site; (v) investigate or settle inquiries or disputes; (vi) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vii) enforce our agreements with you; (viii) protect the rights, property or safety of us or third parties, including our other clients and users of the Site; (ix) provide support for the provision of our Services; (x) carry out recruitment activities; and (xi) use as otherwise required or permitted by law.
We collect and process the following personal data:
- If you are a visitor to the Site
We collect any information about you that you may voluntarily provide us when you contact us using the details on our “Contact” page on the Site or when you sign up to receive our news alerts. This may include your name, contact information (including your email address), demographic information (such as your preferences and interests) and any other information relevant to the operation of our Site and the provision of our Services.
Through our use of cookies, we also automatically collect information regarding your mobile device or computer hardware and software which you have used to access the Site. Please see our Cookie Policy for further information.
- If you have entered into a contract with Antin for our Services
Antin’s clients are corporate entities and as such are not individuals (“data subjects”). However, in providing the Services to our clients we may receive and process personal data about certain individuals in connection with the provision of those Services. For example, part of the subscription process requires our clients to complete a set of subscription documents, which requires disclosure of certain employee names and contact details. We also require lists of authorised signatories as well as certified copies of the passports of those signatories and proof of their address. We also maintain a client database, which includes names, email addresses and telephone numbers of individuals.
- If you are an individual whose personal data may be processed by us as a result of our provision of the Services to others
We may process a variety of different personal data depending on the Services being provided. This may include personal data relating to any of our corporate clients’ or prospective clients’ workers or third party partners. For example, we correspond with our clients’ employees on a day-to-day basis in providing our Services.
- If you are a potential recruit of Antin
We collect information about you such as your name and job title; contact information including email address; curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us; other information relevant to your potential recruitment to Antin. We may also obtain information about you from third-party sources, such as employment research firms, recruiters and, where permitted by law, we may use a third party to carry out background checks to determine your suitability for a position.
We use your personal data for the following purposes:
- Fulfilment of our Services and business communications.
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.
If you subscribe to our Services, we will process personal data provided by you for the purposes of client due diligence and conducting anti-money-laundering checks. We will also use it to identify you when you log into secure areas of our Site and so that we can administer your account with us.
We will also use personal data to communicate with our clients in connection with their investment, including by sending clients quarterly investor reports, relevant fund updates and invitations to investor meetings, as part of our Services.
We may send you marketing information by email about products or services of ours which are similar to the Services you subscribed to (such as information about similar funds you may be interested in), unless you have refused or opted out of receiving these emails at the time you provided us with your data or you have later indicated to us that you do not wish to receive communications in this manner. You can opt out at any time of receiving such communications by contacting us as set out under the “How to Contact Us” section above or following the opt-out instructions included in each communication. We will send you news alerts, other information on new products or services, recommendations about third party services or other promotions only with your consent.
If you are a prospective client, we will use personal data, such as the contact information of individuals within your organisation, to contact you to arrange meetings.
Who do we share your personal data with for this purpose?
We will share your personal data with the following categories of third parties as necessary when providing the Services:
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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 the European Economic Area (“EEA”). For more information about our international data transfer practices, please read Section 8 “International data transfers”;
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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 read Section 8 “International data transfers” ;
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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);
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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;
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Banks who assist us by acting as depositories for client funds; and
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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 read Section 8 “International data transfers”.
What is our legal basis?
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you. We have a legitimate interest in sending our clients emails relating to other products and services we offer which may be of interest to you, but for different marketing emails we will rely on your consent, which you can withdraw at any time as described below. Where we rely on our or a third party’s legitimate interest to process your personal data, we consider the impact on you and will only use your personal data to the extent that our our reasons for using your data do not harm your rights and interests.
- 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 read Section 8 “International data transfers”.
- 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).
What is our legal basis?
It is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best customer service we can to you. Where we rely on our or a third party’s legitimate interest to process your personal data, we consider the impact on you and will only use your personal data to the extent that our our reasons for using your data do not harm your rights and interests.
- 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 read Section 8 “International data transfers”
What is our legal basis?
Where your personal data is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best products and services to you and our other visitors and clients. Where we rely on our or a third party’s legitimate interest to process your personal data, we consider the impact on you and will only use your personal data to the extent that our our reasons for using your data do not harm your rights and interests.
We will only use your location data for insight and analysis purposes where we have your consent to do so.
We use your personal data for recruitment purposes, in particular, to assess your suitability for any position which you may apply for at Antin (including by conducting reference and background checks were required or permitted by applicable law), whether such application has been received by us online, via email, by hard copy or in-person application or through a third party recruitment agency.
If your application is unsuccessful, we will keep your contact details and your resume on file to communicate with you and inform you of current and future career opportunities unless you tell us that you do not want us to keep your data for that purpose. We will also use your data to manage and improve our recruiting and hiring processes pursuant to our legitimate interest in doing so.
We also use your personal data the purposes of reviewing Antin’s equal opportunity profile in accordance with applicable legislation. Antin does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit.
Who do we share your personal data with for these purposes?
We will share your personal data with external recruiters, third parties that undertake background checks and other entities within the Antin group of companies (notably, Antin UK or Antin France, as the context dictates).
What is our legal basis?
Use of your personal data in connection with recruitment is necessary so that we can take steps at your request to enter into a contract we may have with you. We have a legitimate interest in processing personal data during the recruitment process to manage and improve the recruitment process and ensure that we can make the best recruitment decisions, respond to and defend against legal claims and keep your data on file for future opportunities, unless you object to this. Where we rely on our or a third party’s legitimate interest to process your personal data, we consider the impact on you and will only use your personal data to the extent that our our reasons for using your data do not harm your rights and interests.
We will not process any sensitive personal data (such as health data) except where we are able to do so under applicable legislation or with your explicit consent.
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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).
What is our legal basis?
Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties it is in our legitimate interest to do so. Where we rely on our or a third party’s legitimate interest to process your personal data, we consider the impact on you and will only use your personal data to the extent that our our reasons for using your data do not harm your rights and interests. For all other purposes described in this section, use of your personal data is necessary to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal data (special data), we shall obtain your explicit consent to do so.
- 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.
5 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.
6 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.
7 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 Policy 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 Policy 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.
8 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 Policy we will 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.
9 How long do we keep your personal data for?
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 in compliance with our obligations under the EU and UK General Data Protection Regulation (“GDPR”) (or similar legislation around the world) (or for longer as we are required to do so according to 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 and in compliance with our obligations under the GDPR (or similar legislation around the world) (or for longer as we are required to do so according to our regulatory obligations or professional indemnity obligations).
If your data is only useful for a short period (e.g. for specific fundraising campaigns) we will delete it as soon as the data is no longer necessary for the purpose for which it was collected.
10 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.
11 How to access your information and your other rights
You have the following rights in relation to the personal data we hold about you:
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, we may need to charge a reasonable fee.
- 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.
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.
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 Policy), 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.
12 Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time.
To ensure that you are always aware of how we use your personal data we will update this Privacy Policy 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 Policy periodically to be informed of how we use your personal data.
13 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.
