1. Overview
This Privacy Policy is provided by TVM Capital Healthcare (being TVM Capital Healthcare Partners Limited, TVM Capital Healthcare Partners Pte. Ltd. together with its affiliated entities, as the context requires) and it applies to ways in which we interact with individuals (Data Subjects) including, without limitation:
- directors, officers, employees and other representatives of portfolio companies in which TVM Capital Healthcare has made an investment or is considering making an investment;
- individuals applying for or enquiring about and employment with us;
- individual representatives of placement agents and other service providers, whether or not engaged by TVM Capital Healthcare, directors, officers, employees and other representatives of TVM Capital Healthcare; and
- visitors to our website.
Please note that TVM Capital Healthcare may provide additional privacy notices or similar disclosures in respect of certain categories of Data Subjects (e.g. certain investors or prospective investors, certain former or existing employees).
What data do we collect and how?
Personal Data is any information that reasonably can be used to identify you as an individual person (Personal Data). We collect this Personal Data in various ways, including:
- Directly from the Data Subject (e.g. when you voluntarily submit information to our website, or send us an email or other written correspondence); and
- Indirectly from other sources (e.g. from public records or from a counterparty in possession of the data).
In addition we automatically collect certain data from Data Subjects who visit our website, through the use of our data collection tools (Cookies) when you visit the website. Please see ‘Cookies’ below to learn about how we use Cookies on the website.
How and on what basis do we use our Personal Data?
We use your Personal Data for a variety of reasonable and legitimate business purposes, including, but not limited to, the following:
- Complying with legal or regulatory obligations;
- Performing a contract with you or to take steps at your request before entering a contract;
- Communicating with Data Subjects;
- Performing activities relating to client management and administration;
- Investigating and resolving disputes and security issues and enforcing agreements;
- Monitoring and auditing compliance with internal policies and procedures;
- Processing and considering applications of employment.
We endeavour not to use your Personal Data for any purposes inconsistent with this Privacy Policy without your permission.
With whom do we share your Personal Data?
Within TVM Capital Healthcare
We share your Personal Data among TVM Capital Healthcare entities for the purposes set out above.
To Third Parties
We share your Personal Data with third parties in certain circumstances, including:
- Service Providers that perform services on our behalf. We generally require these providers by contract to keep the information confidential;
- Transaction or other corporate events, such as a merger, acquisition, joint venture, or financing or sale of company assets; and
- As required by applicable law or to the government or private parties in connection with a lawsuit, subpoena investigation or similar proceeding, or as part of our legislative or regulatory reporting requirements.
Within TVM Capital Healthcare
We share your Personal Data among TVM Capital Healthcare entities for the purposes set out above.
To Third Parties
We share your Personal Data with third parties in certain circumstances, including:
- Service Providers that perform services on our behalf. We generally require these providers by contract to keep the information confidential;
- Transaction or other corporate events, such as a merger, acquisition, joint venture, or financing or sale of company assets; and
- As required by applicable law or to the government or private parties in connection with a lawsuit, subpoena investigation or similar proceeding, or as part of our legislative or regulatory reporting requirements.
Within TVM Capital Healthcare
We share your Personal Data among TVM Capital Healthcare entities for the purposes set out above.
To Third Parties
We share your Personal Data with third parties in certain circumstances, including:
- Service Providers that perform services on our behalf. We generally require these providers by contract to keep the information confidential;
- Transaction or other corporate events, such as a merger, acquisition, joint venture, or financing or sale of company assets; and
- As required by applicable law or to the government or private parties in connection with a lawsuit, subpoena investigation or similar proceeding, or as part of our legislative or regulatory reporting requirements.
How do we protect your Personal Data
We take the protection of your personal data seriously. We treat your personal data as confidential and in accordance with applicable TVM Capital Healthcare policies and procedures. We use reasonable efforts to ensure that all Personal Data is kept secure and safe from any loss or unauthorized disclosure or use and that Personal Data held by us are stored in a secure and safe place, and accessed only by our authorized employees and transferees.
Keeping your Personal Data current
In general, we seek to ensure that we keep your Personal Data accurate and up to date. However, in order for us to do so, please kindly inform us of, any changes to your Personal Data. You may do so by contacting us through the contact details set out under the ‘Contact’ page of our website.
How long do we keep your Personal Data?
In general, we seek to keep your Personal Data for no longer than necessary in relation to the purposes for which we collect and use the Personal Data (see purposes set out above). TVM Capital Healthcare will retain your Personal Data in accordance with its applicable internal policies and procedures. If you have any specific questions in this regard, please feel free to contact us.
Contact and Complaints
TVM Capital Healthcare takes very seriously any complaints we receive about our use of your Personal Data. Questions, comments, requests or complaints regarding our website, this Privacy Policy and our use of your Personal Data should be addressed to info@tvmcapitalhealthcare.com.
The Site
www.tvmcapitalhealthcare.com is operated from servers in Germany. BY USING THIS SITE AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL DATA IN GERMANY.
This site uses SSL or TLS encryption for security reasons and for the protection of the transmission of confidential content, such as the inquiries you send to us as the site operator. You can recognize an encrypted connection in your browser’s address line when it changes from “http://” to “https://” and the lock icon is displayed in your browser’s address bar.
If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
Please be aware that our website may contain links to other websites hosted by third parties. TVM Capital Healthcare does not control and is not responsible for the content or privacy practices and policies of such third party websites. We encourage you to be aware when you leave our website and to read the privacy policies of each third-party website.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on our websites. This service is provided by Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, USA (“Google”).
reCAPTCHA is used to check whether the data entered on our website (such as on a contact form) has been entered by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, how long the visitor has been on the website, or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.
The reCAPTCHA analyses take place completely in the background. Website visitors are not advised that such an analysis is taking place.
For more information about Google reCAPTCHA and Google’s privacy policy, please visit the following links: https://www.google.com/intl/de/policies/privacy/ and https://www.google.com/recaptcha/intro/android.html.
Additional Information for Residents of the European Economic Area
For the purposes of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 (the GDPR), we act as a ‘data controller’ and our headquarters are located in DIFC, Gate Village, Building 4, PO Box 113355, Dubai, UAE. As a data controller, we are responsible for deciding how we hold and use Personal Data about you.
In respect of the collection, holding, storage, use, and processing of your Personal Data:
- We will process the data lawfully, fairly and in a transparent way;
- We will obtain the data only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- The data we collect will be relevant to the purposes we have told you about and limited only to those purposes;
- We will take reasonable steps to ensure that the data is accurate and kept up to date;
- Subject to applicable legal or other requirements, we will keep the data only as long as necessary; and
- We will use appropriate technical and/or organizational measures to ensure appropriate security of the data.
Data Transfers outside of the EEA
Where your Personal Data is transferred outside the EEA, we seek to ensure appropriate safeguards are in place to adequately protect it, as required by applicable law.
You always have the right to request information about your stored data, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that it be corrected, blocked, or deleted. You can contact us at any time using the address given in the legal notice if you have further questions about the issue of privacy and data protection. You may also, of course, file a complaint with the competent regulatory authorities.
GDPR Data Subject Rights
Under the GDPR, in certain circumstances, you may have individual rights with respect to the Personal Data that we hold. In particular, you may have the right to:
- Request access to any data held about you
- Ask to have inaccurate data amended
- Request data held about you to be deleted, provided the data is not required by TVM Capital Healthcare to perform a contract, defend a legal claim or to comply with applicable laws or regulations
- Prevent or restrict processing of data which is no longer required
- Request transfer of appropriate data to a third party where this is technically feasible
Additionally, you have the right to withdraw consent for any specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
To exercise any of these rights, please contact us using the contact details set out under the “Contact and Complaints” above.
As an EEA resident, you are also entitled to direct any complaints in relation to our processing of your Personal Data to your national local data protection supervisory authority.
Additional Rights under the DIFC Data Protection Law No. 5 of 2020
For the purposes of the DIFC Data Protection Law No. 5 of 2020, we act as a ‘data controller’ and our headquarters is located in DIFC, Gate Village, Building 4, PO Box 113355, Dubai, UAE. As a data controller, we are responsible for deciding how we hold and use Personal Data about you.
Under the DIFC Data Protection Law No. 5 of 2020, in certain circumstances, you may have individual rights with respect to the Personal Data that we hold and you have the right to withdraw consent for any specific processing at any time. These rights include a right to withdraw your consent at any time, as well as the right not only to object to processing, but also to restrict processing in certain circumstances.
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Additional Rights under the Singapore Personal Data Protection Act 2012
For the purposes of the Singapore Personal Data Protection Act 2012, we act as a ‘data controller’. As a data controller, we are responsible for deciding how we hold and use Personal Data about you.
Under the Singapore Personal Data Protection Act 2012, in circumstances, you may have individual rights with respect to the Personal Data that we hold. These rights include the right, on reasonable notice, to withdraw your consent to the collection, use or disclosure of your Personal Data.
Once we have received notification that you have withdrawn your consent, we will inform you of the likely consequences of such withdrawal of consent and no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Cookie Policy
Cookies
Some of our web pages use cookies. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.
Most of the cookies we use are so-called ‘session cookies’. They are automatically deleted after your visit. Other cookies remain in your device’s memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.
You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website.
Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use are stored pursuant to applicable law. The website operator appointed by TVM Capital Healthcare has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors.