EG Manager UK LLP (EG Manager UK LLP or the “Firm”), “we”, “us” and “our” means the entity employing or proposing to employ you on the date that you receive this document, and we are committed to respecting your privacy. This Privacy Notice applies if you are a prospective employee of our organisation.

We are established in the United Kingdom and our registered address is 14 Floral Street, 2nd Floor, Convent Garden, London, United Kingdom, WC2E 9DJ and our company registration number is OC417982.

About this Privacy Notice

For the purposes of data protection law, we are a controller in respect of your personal data. The Firm is responsible for ensuring that we use your personal data in compliance with applicable data protection laws, including but not limited to the retained EU law version of the General Data Protection Regulation 2016/679 (“UK GDPR”) and Data Protection Act 2018.

This Privacy Notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this Privacy Notice.

Where we use the term your “Application” in this notice, we are referring to your application to work at EG Manager UK LLP.

Personal data collected by us

We will collect and process (e.g. obtain, record, use, share or hold etc.) the following personal data about you:

• Information that you provide to us or one of our affiliates. This includes information that you submit to us when you make your initial application and includes:
• personal details such as, but not limited to, your full name, email address, contact details, employment history and qualifications (both academic and professional);
• any other details you provide in support of your Application, including (but not limited to) information contained in your CV and/or covering email and your reasons for applying to us;
• information provided in connection with visa applications in relevant locations; and
• information about your spouse and other family members. If you provide information about your spouse and other family members to us, you agree that you have provided this privacy notice to them to enable them to understand how we will be using their information.
• Information we collect or generate about you. This includes information that is collected in connection with your Application and is likely to include:
• personal data that we collect through your communication and correspondence with us (including but not limited to the content, date and time of your email correspondence); and
• information obtained through any interviews and assessments with you.
• Information we obtain from other sources.
• This may include:
• personal data that we collect from screening, background and/or reference checks we may perform on you as part of the Application or recruitment process, which may include your address history, your credit history, your qualifications (both academic and professional), your previously held directorships (if any);
• recruiting agencies, social media and public sources; and
• a criminal records check.

Uses of your personal data

Your personal data may be stored and processed by the Firm in the following ways and for the following purposes:

• to consider your Application (including, in some cases, verifying your qualifications and references with those third parties you name);
• to support your (and your family members’) move to the relevant location;
• to meet our legal and regulatory obligations;
• to maintain consistent practices and procedures with respect to the collection, use, disclosure, transfer and processing of personal data across all the Firm worldwide. These practices and procedures include the effective recording, management and administration of personal data;
• to maintain consistent practices and procedures with respect to the recruitment of personnel across the Firm, including the performance of human resources and other functions;
• we may process your personal information for the purposes of equal opportunities monitoring; and
• to maintain contact with you in the future and notify you of relevant job vacancies that you might be interested in. Please note that if you do not want us to retain your information, or want us to update it at any stage, please contact us in accordance with the “Contacting us” section.

We are entitled to use your personal data in these ways because:

• we need to in order to take steps in preparation for entering into a contract with you, in particular to consider you for a position;
• we have legal and regulatory obligations that we have to discharge;
• for us to comply with our legal and regulatory obligations, including those of the Firm’s corporate parent Engineers Gate Manager LP, a US SEC-registered investment advisor and US CFTC-registered commodity pool operator;
• we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and/or
• the use of your personal data as described is necessary for our legitimate business interests, such as:
• allowing us to effectively assess your skills, qualifications and/or the strength and merits of your Application and your suitability for the role applied for;
• allowing us to effectively verify your information;
• allowing us to effectively and efficiently administer and manage the operation of our business;
• ensuring a consistent approach to the recruitment of personnel; or
• being able to contact you in relation to your Application and the recruitment process.

Please note, if your Application is successful and you are subsequently offered and accept employment, the information we collect during the application and recruitment process will become part of your employment record.

Special categories of personal data that we collect about you

“Special categories of personal data” are subject to specific protection or restriction by law in certain territories, including the UK. For these purposes, “special categories of personal data” relate to: racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data; data concerning health; or data concerning sexual preferences, sex life or sexual orientation. There are also special rules surrounding data relating to criminal convictions or offences. We will only process special categories of personal data or data relating to your criminal records if permitted by law and only if one of the following conditions is met:

• the processing is necessary for carrying out obligations and specific rights of the Firm in the field of employment law, social security or social protection law (including obligations in relation to public health, health and safety and disability discrimination, the legality of personnel working in a particular jurisdiction, which will involve processing data in relation to nationality, work permits and visas, monitoring equality of racial or ethnic opportunity or treatment, and vetting (where necessary));
• the processing is necessary to protect the vital interests of you or another person where you are physically or legally incapable of giving consent;
• the data in question has been made public by you;
• the processing is necessary for the purpose of, or in connection with, any regulatory requirements, actual or prospective legal proceedings, for the purpose of obtaining legal advice or otherwise for the purposes of establishing, exercising or defending legal rights subject to applicable local legislation or where courts are acting in their judicial capacity;
• the processing is necessary for reasons of substantial public interest on the basis of local law which is proportionate to the aim pursued and which contains appropriate safeguarding measures;
• the processing is necessary for archiving purposes in the public interest or scientific and historical research purposes or statistical purposes; or
• as otherwise permitted by law; and

In each case we will meet any additional local legal requirements and enforce any applicable duties of confidentiality effectively, for example in relation to access to health records.

Disclosure of your information to third parties

We may disclose your personal data to our affiliates for the purposes of:

• the management and administration of our business, including the maintenance of certain records storing personal data;
• enabling the performance of the functions that our business may perform relating to regional or global HR decisions within the Firm; or
• assessing compliance with applicable laws, rules and regulations, and internal policies and procedures within the Firm.

We will take steps to ensure that the personal data is accessed only by employees of our affiliates that have a need to do so for the purposes described in this Privacy Notice and that they are subject to appropriate confidentiality and only use the data for purposes described in this Privacy Notice.

In addition to the above, we may also share your personal data with third parties outside of our corporate group for the following purposes:

• to third party agents or contractors, bound by obligations of confidentiality, in connection with the processing of your personal data for the purposes described in this notice. This may include outsourced HR service providers and consultants, IT and communications service providers, law firms, accountants and auditors (“Third Parties”); and
• to the extent required by law, regulation or court order, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation.

Transfers of personal data outside the UK

Your personal data may be transferred to our international affiliates and the various entities that make up our international network and accessed by personnel authorised by us, and in limited circumstances to our third-party contacts, outside the UK as well as within it, for the purposes identified above.

Where we transfer your personal data outside the UK, it will be protected in a manner that is consistent with how your personal data will be protected by us in the UK. This can be done in a number of different ways, for instance:

• the country to which we send the data is deemed adequate and is covered by UK adequacy regulations (for example, transfers of data to EU countries are permitted on this basis); or
• the recipient may have adhered to binding corporate rules; or
• the recipient has signed an International Data Transfer Agreement (which is a standard set of data protection clauses for restricted transfers), obliging them to protect your personal data.

The personal data that we collect from you may also be otherwise transferred to, and stored at, destinations outside the UK. It may also be processed by individuals operating outside of the UK who work for our affiliates or for one of our suppliers.

In all cases, however, we will ensure that any transfer of your personal data is compliant with the UK GDPR and other applicable data protection laws.

You can obtain more details about the protection given to your personal data when it is transferred outside the UK (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

• the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

In some instances, we may retain your information to consider you for other roles and future opportunities within the Firm which may be of interest to you. If you do not want us to retain your information, or want us to update it at any stage, please contact us in accordance with the “Contacting us” section.

Your rights

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

• the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
• the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
• the right to request that we rectify your personal data if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
• the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request; and
• the right to lodge a complaint with the UK data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.

Further information about your rights may be obtained by contacting the Information Commissioner's Office (ICO) (https://ico.org.uk/).

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to Human Resources or Legal (legal@eglp.com).

Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time, whereby we will make sure that the most recent version may be requested by contacting us as set out in this Privacy Notice.