Last Updated 22nd February, 2022


The purpose of this notice is to provide you with information on our use of your personal data in accordance with the Data Protection Act, 2017 (the “DPA”).

In this document, “we”, “us” and “our” refers to SP Novo PortCo I LP (“PortCo I”), Stonepeak Partners LP (“Stonepeak Partners”) and its affiliates, entities managed by its affiliates and entities set up at the direction of its or their affiliates (collectively, “Stonepeak”) and its or their affiliates and/or delegates and/or nominees.

By virtue of our acquiring participations and commitments in certain facility agreements (the “Loan”) and any associated interactions with us including the recording of electronic communications or phone calls (where applicable) or by virtue of you otherwise providing us with personal information on individuals connected with you (for example directors, trustees, employees, representatives, shareholders, clients, beneficial owners or agents), we have been provided with or you may provide us with certain personal information which constitutes personal data within the meaning of the DPA (“Personal Data”). We may also obtain Personal Data from other public sources. Personal Data includes, without limitation, the following information relating to you and/or any individuals connected with you: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your financing arrangement.

In our use of Personal Data, PortCo I will be characterised as a “data controller” for the purposes of the DPA. PortCo I’s affiliates, nominees and delegates may act as “data processors” for the purposes of the DPA.

How We May Use Your Personal Data

PortCo I, as the data controller, may collect, store and use Personal Data for lawful purposes, including, in particular where this is necessary for the performance of our rights and obligations under the Loan and/or the constitutional and operational documents of PortCo I and      where this is necessary for compliance with a legal and regulatory obligation to which PortCo I is subject (such as compliance with anti-money laundering requirements).

Why We May Transfer Your Personal Data

In certain circumstances we and/or our authorised affiliates, nominees or delegates may be legally obliged to share Personal Data and other information with respect to the Loan with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.

We anticipate disclosing Personal Data to parties who provide services to PortCo I and their respective affiliates (which may include certain entities located outside the Cayman Islands or the European Economic Area). Such parties include Cortland Capital Market Services LLC (also known as Alter Domus) and Novo Asset Finance Pty Limited who may either process personal data on our behalf or for their own lawful purposes in connection with services provided to PortCo I.

The Data Protection Measures We Take

Any transfer of Personal Data by us or our duly authorised affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPA.

We and our duly authorised affiliates and/or delegates shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Personal Data, and against accidental loss or destruction of, or damage to, Personal Data.

Getting In Touch

Should you have any queries or wish to discuss your data protection rights with us, please contact