Privacy Notice

Privacy Notice

Sandell Asset Management Corp. (“SAMC”), Sandell Asset Management Europe Limited (“SAME”), and their affiliates (collectively referred to as “Sandell”, the “Sandell Group”, or “we”) are data controllers with respect to your personal data for purposes of applicable data protection laws, such as the General Data Protection Regulation (Regulation (EU) 2016/679, the “GDPR”). Sandell is responsible for ensuring that it uses your personal data in compliance with such data protection laws.

Sandell’s protection of your personal data is critical to you and to us. Such data will generally be processed where it is provided to Sandell in connection with a potential or actual investment in one or more funds or accounts managed by Sandell (an “Investment”). We maintain the confidentiality of your information and do not sell nor disclose it to anyone except as permitted or required by law or as described in this statement.

This privacy policy provides notice on how we handle your personal data and your rights in relation to that personal data introduced by GDPR. Any changes we may make to our privacy policy in the future will be reflected herein.


What data do we process?

When you or (if different) the investor interact with this website or through representatives of Sandell’s business, you or (if different) the investor may provide us with certain personal information constituting personal data within the meaning of GDPR. This may include, but is not limited to, data such as your name and address, email address, place of birth, date of birth, gender, nationality, photograph, signature, occupational history, job title, income, assets, bank account details, details relating to investment activity, tax residency and tax identification information. This information might be provided in a subscription agreement or in other documents (in connection with your subscription, continued investment, or at other times), face-to-face, via telephone, via email, or otherwise.

We may also collect information relating to your or (if different) an investor’s emails (and related data), call recordings and website usage data.

Our website uses cookies to facilitate easier navigation within the site and provide a higher level of convenience for the visitor. Though Sandell typically only interacts with institutional investors, details of the individuals related to those institutions (employees, directors, consultants, etc.) may constitute personal data under GDPR. It is important that institutional investors provide such persons with a copy of this Privacy Policy to ensure they understand that their personal data will be provided to us and processed by us or our delegates and ensure, if required, that such persons have provided their consent to the processing of personal data by us.

Please note that we may also obtain certain information from other sources. This can include:

  • Information obtained from third-party sources for due diligence purposes as appropriate to the context of our relationship with you, and/or used to form a substantive pre-existing relationship prior to an investment;
  • Information from public websites or other public sources (including third-party agencies such as credit reference agencies, fraud prevention agencies, law enforcement agencies, public databases, registers and records such as Companies House and the FCA Register) and information from sanctions checking and background screening providers;
  • Information received from your or (if different) the investor’s advisers; and
  • Information received from intermediaries.

How we use personal data and who we share it with?

We use personal data held about you for the following purposes:

  • Assessment and processing of your investment, transaction requests in the applicable funds managed by Sandell and other dealings in shares or interests, including for:
    • Assessing investor eligibility or suitability;
    • Performing know-your-client procedures;
    • Facilitating automatic exchange of information for tax (i.e. FATCA or CRS) purposes;
    • Issuing and redeeming shares or interests;
    • Receiving payments from and making payments to an investing entity or intermediaries;
    • Calculating net asset value; and
    • Conducting oversight and audits of the above processes.
  • General business administration, including:
    • Communications with and services provided to investors;
    • Communications with service providers and counterparties, accounting and audit services;
    • Risk monitoring; and
    • Administration of information technology systems.
  • Compliance with legal and regulatory obligations, industry standards, and best practices, including:
    • Know-your-client requirements;
    • Automatic exchange of information (tax) requirements; and
    • Data retention and archival requirements.

We may share your personal data within the Sandell group for the purposes described above. In addition, we may also share your personal data in accordance with the same purposes but outside of the Sandell group as further described below:

  • With the applicable fund administrator and its affiliates;
  • With third-party advisors and contractors for the purposes of them providing services both to us and or the applicable fund. Such parties include, for example, accountants, law firms, and other professional advisors, IT and communications providers, and counterparties;
  • With depositories, securities exchanges, clearing or settlement systems, counterparties, dealers and others where disclosure of your personal data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
  • To the extent required by law or regulation, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal right; and
  • Where we sell some or all of our business or its assets, in which case it may be necessary to disclose your personal data in the course of the buyer’s due diligence process.

While some of these third parties will process your personal data in accordance with Sandell’s instructions, others will themselves be responsible for their use of your personal data. These persons may be permitted to disclose this data to other parties.


Transfer of personal data

Sandell is a global business. As such, SAME may transfer data outside the UK and the European Economic Area (EEA), including to SAMC in the United States and to other ex-EEA service providers. Where we transfer your personal data, we will do so in accordance with GDPR and other legal requirements, which may include the following:

  • Commission as offering an adequate level of protection for personal data;
  • the recipient might have signed up to a contract based on model or standard contractual clauses approved by the European Commission, obliging it to protect your personal data; or
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

Please note that your data may also be disclosed to relevant tax and regulatory authorities as per legal or regulatory requirement that apply to the processing of your personal data.

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


Data protection measures we take

We, our affiliates and our service providers shall apply appropriate information security measures designed to protect data from unauthorized access by third-parties or computer corruption.


Our retention of your personal data

We, our affiliates and our service providers may retain your personal data for the purposes described above for as long as is necessary.

In particular and without limitation to the foregoing, certain laws and regulations may impose minimum periods for which Sandell and certain service providers with which Sandell engages, including fund administrators, must retain your personal data.


Your rights

You have certain rights regarding our use of your personal data as listed below. To exercise these rights or, if you would like to contact us regarding your personal data, please email us.

  • The right to access your data (in an easily readable form);
  • The right to have your data erased;
  • The right to request that we correct your data where it is inaccurate or incomplete;
  • The right to restrict the use of your data;
  • The right to withdraw any consent given to the processing of your data (where applicable), in absence of another legitimate reason for doing so (e.g. we may need to process data to comply with a legal obligation);
  • The right to receive information regarding any entities we disclose your data to;
  • The right to lodge a complaint with the relevant data protection regulator if you believe that we have infringed upon any of your rights; and
  • The right to object to the processing of your data.

Please note that the rights for you to have your data erased (the "right to be forgotten") or to object to the use of your data that applies in some contexts under GDPR may not always be applicable to the personal data you provide to us, given the specific nature of the purposes for which we use the data, as described above.

Should we wish to use your personal data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.

You may exercise your rights by contacting us using the details set out below. You can also access additional information concerning your rights by contacting an EU data regulator such as the UK’s Information Commissioner’s Office, or by searching their website at ico.org.uk.



Sandell reserves the right to amend or modify this policy at any time and without prior notification. This policy is intended to comply with the GDPR. The examples described within this policy are intended for illustrative purposes only and are not intended as exclusive. You may be entitled to rights or protections under other privacy laws in the applicable jurisdiction in addition to those described herein.

For purposes of the applicable data protection laws, the entities responsible as controllers and/or processors of your personal data are:

United States: Sandell Asset Management Corp.
United Kingdom & EEA: Sandell Asset Management Europe Limited

There may also be times where other third-parties assist with certain processes and may use your personal data for purposes they have determined to be lawful and necessary.

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 contact Investor Relations at IR@sandellmgmt.com.