Privacy Policy

1 Introduction

1.1 Who we are

We are GridLink Interconnector Limited (“GridLink”, “we”, “us”), a limited company incorporated and registered in England and Wales with company number 10181689 and registered office at 25 East Street, Bromley, England, BR1 1QE.

1.2 Purpose of this Privacy Policy

We take your privacy very seriously. As such, we ask that you read this Privacy Policy carefully as it contains important information about:

what personal data we may collect from you;
how we will use, store and protect your personal data;
with whom we may share personal data; and
your rights under relevant data protection laws.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

2 Lawful basis for processing

Under data protection laws, we must have a legal basis in order to process your personal data. The legal bases on which we may process your data are:

Legitimate interest: in order to carry on GridLink’s business and related activities.
Consent: where you have consented for us to process your personal data for one or more specific reasons.
Performance of a contract: in order to perform a contract that GridLink may have with you.
Legal obligation: where processing of the data is required by law.

3 What data we may collect from you

We may collect and process the following personal data:

your name, email address, telephone number(s), organisation, role and information related to our business relationship with you;
for clients and commercial counterparties, the personal data of its representatives and staff, including the data set out above as well as date of birth, gender, financial information, visual images (such as copies of passports) and data contained in identity documentation;
cookie data (please see our Cookies Policy on our website www.gridlinkinterconnector.com for further information); and
technical data such as internet protocol (IP) address, 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 our website.

4 How we collect information from you

We collect your personal data in a number of ways:

as you browse the GridLink website certain information is collected automatically using cookies, server logs and other similar technologies. Please see our Cookies Policy on our website for further information;
during the communications between us, such as via email, telephone, correspondence or in meetings;
any personal information you provide to us during your relationship with us as a commercial counterparty of us; and
from third parties/public sources:
- technical data may be obtained from the following parties:
  - our website management provider,
  - data analytics providers, such as Google Analytics, and
  - identity and contact data from publicly availably sources such as internet searches and Companies House.

5 How we use your personal data

We may use your personal data for the following purposes:

to contact you to discuss any GridLink services and to respond to any queries you have raised;
where you are a commercial counterparty of GridLink:
- to carry out necessary anti-money laundering and anti-fraud checks, including any periodic updates of the same,
- to enable us to conduct day-to-day business activities with you, and
to personalise your experience on the GridLink website; and
as we believe to be necessary or appropriate:
- in order to comply with a legal obligation. This applies where the processing is necessary for us to comply with the law,
- to enforce or apply this Privacy Policy, and
- to protect our legitimate rights, privacy, property or safety, and/or those of a third party and your rights do not override those interests.

6 Marketing

We may contact you about our services where we are legally entitled to do so and it is in legitimate interests to provide such information to you. In some cases, we may obtain your consent for such marketing communications.

If you do not wish to be contacted in this way, you can tell us by contacting us at privacy@gridlinkinterconnector.com. We will process your request to be opted-out of such marketing communications within 30 days of receipt.

Where you opt out of receiving these marketing communications, we may still process your personal data for other required purposes, as specified in section 5 above.

7 Third party links

The GridLink website may contain links to and from other applications, plug-ins and websites of other networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they (and any services that may be accessible through them) have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these apps, websites or services. Please check these policies before you submit any personal data to these websites or use such services.

8 Retention of your data

We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for legal (including regulatory) reasons. When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

When we determine that personal data can no longer be retained (or where you request us to delete your data in accordance with your right to do so (please see section 12 below for more information)), we ensure that this data is securely deleted or destroyed.

For more details about our retention periods, please contact us at privacy@gridlinkinterconnector.com.

9 Accuracy of your data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

10 Security of your data

We seek to ensure that we have appropriate organisational and technical security measures to protect your personal data.

In the unlikely event of a data breach, we will take steps to mitigate any loss or destruction of data and, if required, will notify you and any applicable authority of such a breach.

11 Transfer of your data

Transfers within our group

GridLink is 100% owned by iCON Infrastructure Partners III, L.P., part of the iCON Infrastructure LLP (“iCON”) group, a limited company incorporated and registered in England and Wales with company number OC364705 and registered office at 5th Floor 15 Golden Square, London, England, W1F 9JG. We may share your data with other companies and branches within the iCON group, including our:

branch based in Düsseldorf, Germany;
branch based in New York, United States of America;
our subsidiary general partner entities currently based in Guernsey; and
our Canadian subsidiary, iCON Infrastructure Canada, Inc.

Transfers to third parties

There may be circumstances in which we may also need to share your personal data with certain third parties, including third parties located outside of the UK and the European Economic Area (EEA).
The third parties to which we may transfer your personal data include:

Suppliers. We employ other companies and individuals to perform functions on our behalf, including our software suppliers, data hosting providers, data analytics providers, and anti-money laundering tools;
Fund administrators and other service providers who assist us or our subsidiaries with the performance of services related to the investment funds which iCON advises and meeting business operational needs;
Banks who assist us or our subsidiaries by acting as depositories for client funds;
Other professional advisors such as accountants, lawyers, consultants and other business advisors engaged by us or our subsidiaries; and
Other third parties where required under law or applicable regulation, or in connection with legal or regulatory proceedings.

The security of your data is important to us and iCON. We will, therefore, only transfer your data to such third parties if:

the third party has agreed to comply with ours and or iCON’s instructions, required data security standards, policies, and procedures and put adequate security measures in place;
the transfer complies with any applicable cross border transfer restrictions and suitable safeguards have been put in place; and
a written contract containing suitable obligations and protections has been entered into between the parties.

As mentioned above, we or iCON will only transfer your data where suitable safeguards have been put in place. These safeguards are intended to ensure a similar degree of protection is afforded to your data wherever it may be transferred and include:

only transferring your personal data to countries which have been deemed to provide an adequate level of protection for personal data by the European Commission;
where your data will be transferred by iCON outside of the EEA, entering into specific contractual terms which have been approved by the European Commission and which give personal data the same protection as within the EEA; or
where your data will be transferred to the US, ensuring that the third party to which we are transferring your data is part of the Privacy Shield.

We may also share your personal information with a purchaser or potential purchaser businesses connected with iCON or its subsidiaries and in some circumstances, we may have to disclose your personal information by law, either because our regulator, the courts or other law enforcement agency has asked us for it, or to enforce our legal rights.

For more information on the safeguards used by iCON when transfers of personal data to third parties, please contact us at privacy@iconinfrastructure.com.

12 Your rights

You have certain rights in relation to the personal data GridLink process and hold about you. These include:

Right to rectification: you have the right to require GridLink to correct any inaccuracies in your data.
Right to erasure: you have the right to require GridLink to delete your data, subject to certain legal requirements.
Right to restriction of processing: you have the right to require GridLink to restrict the way in which GridLink processes your personal data. You may wish to restrict processing if, for example:
- You contest the accuracy of the data and wish to have it corrected;
- You object to processing but GridLink is required to retain the data for reasons of public interest; or
- If you would prefer restriction to erasure.
Right to data portability: you have the right to obtain from GridLink easily and securely the personal data we hold on you for any purpose you see fit.
Right to object to processing: you have the right to require GridLink to stop processing your personal data should you wish the data to be retained but no longer processed.
Right of access: you have the right to request access to personal data that GridLink may process about you.
Right to withdraw consent: you have the right at any time to withdraw consent allowing GridLink to process your personal data.

If you would like to exercise any of the above rights, please contact GridLink at privacy@gridlinkinterconnector.com. We will respond to requests made by you within one month.

13 Amendments to this Privacy Policy

No changes to this Privacy Policy are valid or have any effect unless agreed by GridLink in writing. GridLink reserves the right to vary this Privacy Policy from time to time. Our updated terms will be displayed on the GridLink website. It is your responsibility to check this Privacy Policy from time to time to verify such variations.

14 Questions in relation to this Privacy Policy

You should also be aware that you have the right to raise any concerns in relation to how GridLink processes your personal data to the Information Commissioner’s Office (ICO).
GridLink, through iCON, has appointed a data privacy lead (DPL) who is responsible for dealing with any such concerns, in addition to overseeing questions in relation to this Privacy Policy and handling requests in relation the exercise of your legal rights. If you have any concerns, questions, or requests, please contact the DPL using the details set out below.

GridLink Interconnector Limited
25 East Street,
Bromley,
England,
BR1 1QE

Email address: privacy@gridlinkinterconnector.com

Cookies Policy

This website (www.gridlinkinterconnector.com) (‘the website’) is brought to you by GridLink Interconnector Limited (“GridLink”, “us”, or “we”) and you should be aware that it may contain cookies. Should you wish to block cookies on this website, you may do so by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, please note that, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all, or parts, of the website. For more information about the use of cookies and how to disable them, please refer to the guidance on the allaboutcookies.org website.

What is a cookie?

Cookies which are small text files which are downloaded onto the hard drive of your computer, smart phone, or any other mobile device you use to access a website. The cookies used on this website may store information about your device’s operating system, browsing behaviour, connection type, and IP address, but do not collect or store any personally identifiable information.

What type of cookies are used?

Cookies perform many different roles.
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).
Google Analytics helps us to measure how you interact with the website. As you navigate the website, Google Analytics allows us to record information about the pages you have seen. It uses HTTP Cookies to ‘remember’ what you have done on previous pages on the website. For example, to distinguish between users of the website, remember the number and time of previous visits and track how long you have viewed the website for. This information is all anonymised.

Why are cookies used?

We use these cookies to understand more about website traffic and usage. The information
generated by the cookies on this website may also be used by GridLink for website analytics purposes.

When do cookies expire?

Cookies can remain on your computer for different periods of time. The cookies used on this website are ‘permanent cookies,’ meaning that they survive after your browser is closed.

How do I block cookies?

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Last updated 10 March 2021