Compliance

Privacy Policy

Welcome to Paladin Capital Group’s Privacy Policy.

What does this Privacy Policy Cover?

Paladin Capital Group respects your privacy and is committed to protecting our Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our website (“Site”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

Who we are and how to contact us.
Your rights relating to your Personal Data.
Marketing communications preferences.
What Personal Data we collect.
How we use your Personal Data and why.
What happens when you do not provide necessary Personal Data.
Personal Data from Third Party Sources.
How we use cookies and other tracking or profiling technologies.
Who we share your Personal Data with.
How we keep your Personal Data secure.
How long we store your Personal Data.
Our policy on children.

This Privacy Policy aims to give you information on how Paladin Capital Group collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

Who we are and how to contact us.

Who we are.

Paladin Capital Group is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either Paladin Capital Group “we”, “us” or “our” in this Privacy Policy).

Our address is: United States: 2000 K Street NW, Suite 500, Washington, DC 20006 and United Kingdom: 5 Merchant Square, 12th Floor
London, UK W2 1AY.

How to contact us.

You can contact Paladin Capital Group by emailing: dpo@paladincapgroup.com.

Our EU representative for Paladin Capital Group’s non-EU entities is: Paladin Capital Group (UK) LLP. Our EU representative can be contacted directly by emailing them at the following address: dpo@paladincapgroup.com.

Your rights relating to your Personal Data.

If you are based in the EU, in certain circumstances you have the right to:

Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact at dpo@paladincapgroup.com.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: dpo@paladincapgroup.com. We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

Marketing communications preferences.

You can ask us to stop sending you marketing messages at any time by sending us an email to dpo@paladincapgroup.com.

What Personal Data we collect.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Category of Personal Data collected	What this means
Identity Data	First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data	Your home address, work address, billing address, email address and telephone numbers.
Marketing and Communications Data	Your preferences in receiving marketing from us and our third parties and your communication preferences.
Technical Data	Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.
Finance Data	Your bank account details, banking instructions and the funds available to you to invest in our portfolio companies.
Transaction Data	Details of investments you have made in our portfolio companies.

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

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). Nor do we collect any information about criminal convictions and offences.

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, 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 update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data? In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

Generally, we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose	Category(ies) of Personal Data involved	Why do we do this	Our legal basis for this use of data
Account Creation	· Identity Data · Contact Data	To register you as a new investor.	Contractual Necessity.
To process payments for investments into portfolio companies.	· Identity Data · Contact Data · Finance Data · Transaction Data	To process and deliver your investment.	Contractual Necessity.
Fraud Prevention	· Identity Data · Contact Data	To keep our website, our services and associated systems operational and secure.	Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
Troubleshooting	Technical Data	To track issues that might be occurring on our systems.	Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Site and associated systems and services.
Marketing	· Identity Data · Contact Data · Marketing and Communications Data	To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.	Legitimate Interests. We have a legitimate interest in providing you with updates on Paladin Capital Group.

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third party data source

Publicly available?

Category(ies) or other types of personal data received.

Social media, e.g., LinkedIn, Twitter, Facebook

Yes

· Identity Data

· Contact Data

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie

Purpose

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

We share your Personal Data within the Paladin Capital Group. This will involve transferring your data outside the European Economic Area (“Europe”).

In addition, many of our external third parties are based outside of Europe so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data outside of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented

We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe.
Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.

Recipients	Category(ies) of Personal Data we share.	Why we share it	Location(s)
Our Affiliates	· Identity Data · Contact Data · Technical Data · Finance Data · Transaction Data	Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc).	· Within Europe · The United States
IT Service Providers	· Identity Data · Contact Data · Technical Data · Finance Data · Transaction Data	Our service providers provide us with IT and system administration services.	· Within Europe · The United States
Financial and legal service providers	· Identity Data · Contact Data · Transaction Data	Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services.	· Within Europe · The United States
HM Revenue & Customs, regulators and other authorities	· Identity Data · Contact Data · Transaction Data	Authorities may require reporting of processing activities in certain circumstances	· Within Europe

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data	Retention period
Marketing and Communications Data	For so long as you remain a customer of ours.
Contact Data	For so long as retention is necessary to fulfil the Purposes/Use for which it is used

Our policy on children.

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.

Paladin Capital Group (UK), LLP MIFIDPRU 8 Disclosure, January 2024

Introduction:

The Financial Conduct Authority (“FCA” or “regulator”) in the Prudential sourcebook for MiFID Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Paladin Capital Group (UK), LLP (“Paladin UK” or the “Firm”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance with which the Firm must comply, further to those prudential requirements.

Paladin UK is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices.

The purpose of these disclosures is to give stakeholders and market participants an insight into the Firm’s culture and to assist stakeholders in making more informed decisions about their relationship with the Firm.

This document has been prepared by Paladin UK in accordance with the requirements of MIFIDPRU 8 and is verified by the Paladin UK Board. Unless otherwise stated, all figures are as at the Firm’s financial year-end, 31 December 2023.

Remuneration Policy and Practices:
Overview:

As an SNI MIFIDPRU Investment Firm, Paladin UK is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). The purpose of the remuneration requirements is to:

• Promote effective risk management in the long-term interests of the Firm and its clients;
• Ensure alignment between risk and individual reward;
• Support positive behaviours and healthy firm cultures; and
• Discourage behaviours that can lead to misconduct and poor customer outcomes.

The objective of Paladin UK’s remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to its clients.

In addition, Paladin UK recognises that remuneration is a key component in how the Firm attracts, motivates, and retains quality staff and sustains consistently high levels of performance, productivity, and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and provide its greatest competitive advantage.

Paladin UK is committed to excellence, teamwork, ethical behaviour, and the pursuit of exceptional outcomes for its clients. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude, and results.

Characteristics of the Firm’s Remuneration Policy and Practices:

Remuneration at Paladin UK is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial performance.

The below table summarises the financial and non-financial criteria of performance used across the Firm in assessing the level of variable remuneration to be paid:

Firm Financial Performance Criteria: Profitability of the firm
Firm Non-Financial Performance Criteria: None
Individual Financial Performance Criteria: Investment portfolio performance
Individual Non-Financial Performance Criteria: Deal sourcing, teamwork, portfolio support, performance vs. objectives

The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.

Governance and Oversight:

The Paladin UK Board is responsible for setting and overseeing the implementation of Paladin UK’s remuneration policy and practices. In order to fulfil its responsibilities, the Paladin UK Board:

• Is appropriately staffed to enable it to exercise competent and independent judgment on remuneration policies and practices and the incentives created for managing risk, capital, and liquidity.
• Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm.
• Ensures that the Firm’s remuneration policy and practices take into account the public interest and the long-term interests of shareholders, investors, and other stakeholders in the Firm.
• Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values, and interests of the Firm and of its clients.

Paladin UK’s remuneration policy and practices are reviewed annually by the Paladin UK Board.

Quantitative Remuneration Disclosure:

For the financial year 1 January to 31 December 2023, the total amount of remuneration awarded to all staff was £242,670, the full amount of which was related to the fixed component of remuneration. £33,200 was awarded in January 2024 in variable remuneration relative to 2023 performance. For these purposes, ‘staff’ is defined broadly, and includes, for example, employees of the Firm itself and directors.