Tiger Infrastructure Partners LP (“Tiger”) is committed to protecting your personal data and considers privacy to be fundamental to our relationship with you.
This privacy notice has been prepared to inform our Limited Partners, clients, investors, website users, customers and suppliers (“you”), how Tiger collects, uses and shares your personal data, and the rights you have in relation to it.
This privacy notice provides general information about how Tiger handles your personal data, however, if you have subscribed for an investment to one of our Funds, please also consult your subscription documents for further information about how Tiger handles your personal data in relation to that specific Fund.
Tiger (together with its affiliates and employees) is a “controller” of personal data you provide to Tiger. That means Tiger decides the “how” and “why” of the processing of your personal data.
1. What is personal data?
Personal data means any information about a living individual from which such individual can be identified.
Examples of personal data include a person’s name, date of birth, place of residence, nationality, telephone number, tax number and individual identification documents. If a piece of data is not, of itself, able to identify an individual but can be combined with other data to identify an individual, then all of that data will be personal data.
2. Types of personal data Tiger collects
Tiger collects, handles, stores, and transfers (known as “processing”) your personal data when, for example, you contact Tiger, apply for or subscribe to an investment with Tiger, or provide or supply a service to Tiger (see below for more information about how Tiger collects personal data about you).
Where you subscribe to an investment with Tiger as a Limited Partner, Tiger may also process information which you provide to Tiger about your individual beneficial owners, representatives or other associated individuals (“associated individuals”). Where you provide personal data of associated individuals, you should make such individuals aware of the contents of this privacy notice.
The personal data about you, or your associated individuals, which Tiger processes may include, but is not limited to:
- Personal details (such as name, address, date of birth, place of residence, domicile, address, nationality and telephone number);
- Social security number, national insurance or other tax identifier;
- Financial information (such as assets and income);
- Payment information (such as bank account details);
- Transactions with Tiger (such as investments, withdrawals, performance and account balances);
- Instructions or requests received by Tiger in relation to your investment;
- Documentary data (i.e., passport, driver’s license or other forms of identification);
- Public records (or openly accessible data) such as the Electoral Register;
- Social and/or demographic (profession, work, nationality, income);
- Historical information (i.e., previous names and addresses); and
- Technical information (such as your internet protocol address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other similar identifying information required for your device(s) to communicate with our website).
3. How personal data is collected
Typically, Tiger will collect personal data verbally, electronically or in writing from and/or about you or your associated individuals in the following ways:
A. Through direct interactions when you provide personal data by filling in forms, entering into contracts or during correspondence with Tiger. This includes when you:
- Enter into an agreement with Tiger such as a subscription agreement, partnership agreement, management agreement, or any side letters;
- Complete documents and questionnaires related to a contract, for example “know your customer” documentation or tax forms;
- Use products and services provided by Tiger; or
- Have meetings or calls with Tiger.
B. Through using our website when Tiger collect information using cookies or similar technologies which tell Tiger about your equipment, browsing actions and patterns.
C. Through third parties such as:
- Fraud prevention agencies;
- Placement agents, consultants or personal financial advisors;
- Third party firms which provide background checks; and
- Publicly accessible sources, such as databases.
4. Consequences where personal data is not provided
Certain personal data will be necessary for Tiger to fulfill their obligations under an agreement with you, to manage your investment in one of their Funds, and/or to comply with their statutory obligations. Failure to supply any personal data necessary for these purposes may mean that you are unable to enter into or continue your investment with Tiger, or that Tiger is unable to supply or receive any goods or services which you or Tiger have requested.
5. How Tiger uses your personal data
Under the Data Protection Laws, Tiger may only process personal data where Tiger has a legal basis for doing so. The legal basis on which Tiger may rely include where it is necessary to process personal data because:
- Tiger has a contract with you (such as where personal data must be processed in order to perform obligations under a subscription agreement);
- Tiger has a legal obligation (such as where personal data must be processed to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations, including confirming your identity and source of wealth); and
- Tiger or a third party has a legitimate interest in processing the information and your interests and fundamental rights do not override those interests.
The following table sets out the ways in which Tiger may use your personal data:
Purpose | Lawful basis for processing |
To on-board you as a new client. | To fulfill our contract with you To fulfill our legal obligations to prevent financial crime and the financing of terrorism. |
To manage your account. | To fulfill our contract with you. |
To monitor your investment on an on-going basis. | To fulfill our contract with you. |
To contact you about your investments. | To fulfill our contract with you To fulfill our regulatory obligations. |
To contact you about other products and services Tiger thinks you may be interested in based on products or services you have previously acquired from Tiger or in which you have expressed an interest. | Necessary for our legitimate interests in developing our products and services. |
To purchase products from our suppliers. | To fulfill our contracts with suppliers. |
To use third party service providers (see below). | To fulfill a contract with you. Necessary for our legitimate interest in managing our Funds. |
Tiger will only use your personal data for the purpose for which it was collected and will only use it for another reason if Tiger believes that new reason is compatible with the original purpose.
If Tiger intends to use your personal data for a non-related purpose, Tiger will tell you about that purpose and explain the legal basis under which Tiger intends to process the personal data.
6. How personal data is shared with third parties
In order to provide services to you, Tiger may provide your personal data to third parties that assist Tiger and that have a need for such information, such as a broker, custodian, lawyer or accountant.
Generally, Tiger will only provide personal data to third parties as permitted or required under an agreement with you and on a “need to know” basis where this is required in the normal course of our activities or is otherwise permitted or required pursuant to applicable law and/or regulation and our related policies and procedures.
Tiger may share your personal data with the following classes of third parties:
- External legal counsel or other professional advisors and their affiliates;
- Companies that assist with processing transactions, such as custodians or administrators;
- Firms that provide background checks for due diligence and anti-money laundering purposes;
- Auditors;
- Brokers;
- Our group companies;
- Outsourced IT consultant firms;
- Any third party to whom Tiger assigns or novates any of our rights or obligations; and
- Any government, regulatory agency, enforcement or exchange body or court where Tiger is required to do so by applicable law or regulation or at such body or court’s request.
Certain third parties which receive personal data (for example, a custodian or administrator), may themselves be subject to regulatory requirements (such as anti-money laundering) or requests from competent bodies which require the disclosure of your personal data. Such third parties may also monitor and record calls and electronic communications for their own quality, business analysis, training, investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution. In some cases (for example, the reporting of a suspicious transaction pursuant to applicable anti-money laundering laws) these third parties may act as an independent controller of Limited Partner personal data.
7. Sending your information outside of the European Economic Area (“EEA”)
Certain third parties with which Tiger shares personal data as described in this privacy notice may include parties established in countries outside of the EEA (such as the United States) where data protection laws may not exist or where such laws may be of a lower or different standard than those in the EEA.
Where this is the case, Tiger will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other applicable data protection law. This may include entering into the EU Standard Contractual Clauses.
Certain countries outside the EEA such as Guernsey or the United States (subject to the Privacy Shield framework) have been determined as offering an adequate level of data protection by the European Commission. In respect of transfers of your personal data from the EEA to these jurisdictions, additional safeguards may not be required.
Our Chief Compliance Officer can be contacted using the details above to provide further information on such safeguards if required.
8. Marketing
Tiger may want to contact you about products or services where Tiger feels it will be of interest to you. Tiger may use you or your associated individuals’ personal data to communicate with you if Tiger has either consent for doing so or a ‘legitimate interest’.
As a commercial enterprise, Tiger has a legitimate interest in contacting our Limited Partners about products or services where Tiger believes such product or service would be of interest or beneficial for that Limited Partner.
You are free to opt-out of these communications at any time by contacting the Chief Compliance Officer.
9. Storing your information
Your personal data will be retained no longer than necessary pursuant to applicable law and regulation and our policies and procedures, in each case having regard to the purpose for which your personal data was obtained.
10. Security
Tiger has put in place appropriate security measures to protect personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Tiger will deal with any suspected personal data breach in accordance with data protection laws and will notify you, and/or other regulators, where legally required to do so.
11. Your rights
You are provided with a number of different rights under data protection law in relation to your personal data (depending on your jurisdiction). These allow you:
- To access your personal data;
- To request that Tiger correct your personal data;
- To request that Tiger erase your personal data;
- To object to the processing of your personal data;
- To request a restriction in the processing of your personal data;
- To request a transfer of your personal data; and
- To withdraw your consent for certain types of processing.
If you wish to exercise any of these privacy rights or have any questions about this privacy notice or the personal data Tiger holds about you, please contact Tiger’s Chief Compliance Officer using the following details:
Name: Jason Kaslow
Email address: jkaslow@tigerinfrastructure.com
Contact telephone number: (212) 201-2187
Postal address: Tiger Infrastructure Partners LP
717 Fifth Avenue, floor 12A
New York, New York 10022
You have the right to make a complaint at any time to the data protection authority in your jurisdiction, details of which can be found online. In the UK, this is the Information Commissioner’s Office and in Guernsey this is the Office of the Data Protection Commissioner. Tiger would, however, appreciate the chance to deal with your concerns before you approach any data protection authority, so please contact Tiger in the first instance.
Where appropriate, this privacy notice may be updated by Tiger from time to time. This privacy notice was last updated on April 3, 2020.
You will not have to pay a fee to access your personal data or to exercise any of your other rights, however Tiger may charge a reasonable fee if the request is clearly unfounded, repetitive or excessive.
Tiger may also need to seek further information from you to confirm your identity before providing any personal data or responding to a request.