Privacy Notice

1. Who we are
This website is published by Sigma Global Limited, a company incorporated in the Isle of Man with registered number [number] and registered office at [address] ("we", "us", "our"). We are the controller of the personal data described in this notice.

"Endurance Capital" is a trading name and is not a legal entity. Please see our Legal and Regulatory Information page.

You can contact us about this notice at info@endurancecapital.co.uk, or by post to the Directors, Sigma Global Limited, [address], Isle of Man.

2. What this notice covers
This notice explains how we handle personal data collected through this website, including our enquiry form and correspondence with us by email or telephone.

It does not cover the websites or the data handling of any portfolio company. Each portfolio company is separately owned and independently managed and is responsible for its own privacy practices.

3. The personal data we collect
Information you give us. If you complete the enquiry form, we collect your name, email address, telephone number and the content of your message. If you contact us by email or telephone, we collect the information contained in that correspondence, which may include your name, contact details, your role, your employer, and information about a business or transaction you wish to discuss.

Information collected automatically. Our hosting provider records technical data including your IP address, browser and device type, the pages you visit and the date and time of your visit.

We do not ask for, and do not want, special category data such as information about health, ethnicity, religion or political opinions, and we ask that you do not include it in your message. We also ask that you do not send us confidential or price-sensitive information until confidentiality arrangements have been agreed in writing.

4. Why we use your personal data, and our lawful basis
[Purposes and lawful-basis detail to be inserted.]

Where we rely on legitimate interests, we have considered whether those interests are outweighed by your interests, rights and freedoms, and have concluded that they are not, principally because the data involved is limited business contact information provided by you, in a business context, for the purpose of engaging with us. You can ask us for further information about that assessment.

5. Who we share it with
We may share your personal data with: service providers acting on our instructions, including the administrator of our corporate and trust structures in the Isle of Man, our website developer and hosting provider, and our email, IT and document storage providers; other Endurance Entities and their directors, officers, employees and trustees, where relevant to your enquiry — in particular members of the investment team based in South Africa; our professional advisers, including lawyers, accountants and corporate finance advisers, where relevant to a potential transaction; and regulators, tax authorities, courts and law enforcement, where we are required or permitted to do so.

We do not sell personal data and do not share it for advertising purposes.

6. Transfers outside the United Kingdom
We are established in the Isle of Man, and members of our investment team are based in South Africa. Your personal data will therefore be transferred outside the United Kingdom.

Transfers to the Isle of Man are covered by the United Kingdom's adequacy regulations for that jurisdiction. South Africa is not covered by adequacy regulations, and for transfers there we rely on the International Data Transfer Agreement issued by the Information Commissioner, together with an assessment of the protections available in that jurisdiction. You can ask us for further details of the safeguards we use.

7. UK representative
We are established outside the United Kingdom. We have considered whether we are required to appoint a representative in the United Kingdom under Article 27 of the UK GDPR and have concluded that we are not, because our processing of the personal data of individuals in the United Kingdom is occasional, is limited to business contact information and correspondence provided to us voluntarily, does not involve special category data or personal data relating to criminal convictions or offences on any scale, and is unlikely to result in a risk to the rights and freedoms of individuals.

We keep that assessment under review. You can contact us directly using the details in section 1, and we will respond to any request or complaint from an individual in the United Kingdom as if it had been made to a representative.

8. How long we keep it
We keep enquiry correspondence for [24 months] from our last substantive contact with you, unless a transaction proceeds or is under active consideration, in which case we keep the relevant records for [seven years] from completion or from the date the matter is closed, so that we can comply with legal, tax and regulatory requirements and deal with any claim. Technical website logs are kept for [period].

9. Your rights
Under the UK GDPR you have the right to ask us for a copy of the personal data we hold about you; to have inaccurate data corrected; to have your data erased in certain circumstances; to restrict or object to our processing, including where we rely on legitimate interests; to receive certain data in a portable form; and to withdraw any consent you have given. We do not make decisions about you by automated means.

To exercise any of these rights, contact us using the details in section 1. We will respond within one month. There is normally no charge.

If you are unhappy with how we have handled your personal data you can complain to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, or at ico.org.uk. We would ask you to raise it with us first so that we can try to resolve it.

10. Cookies
Our website uses only cookies that are strictly necessary for it to function. It does not use analytics or advertising cookies. Strictly necessary cookies do not require your consent. [To be confirmed with the hosting provider before publication.]

11. Security
We use appropriate technical and organisational measures to protect personal data, including access controls, encrypted transmission of form submissions and contractual obligations on our service providers. No transmission over the internet can be guaranteed to be completely secure, which is one reason we ask you not to send confidential information to us before confidentiality arrangements are in place.

12. Unsolicited information
If you send us information about a business or an opportunity that we have not asked for, we will use it only to consider whether we wish to engage with you and to respond to you. We are not able to treat unsolicited material as confidential, and receiving it does not create any obligation on our part or any relationship between us. Any confidentiality arrangement must be agreed separately in writing.

13. Changes to this notice
We may update this notice from time to time. The version in force is the one published on this page, and we will change the date at the top when we do.