Providence Strategic Growth Capital Partners L.L.C. (a limited liability company incorporated in Delaware, USA), together with associated offices practicing under the “PSG” or “Providence Strategic Growth” names in other jurisdictions, its affiliated investment advisers and the funds which it manages (each a “Fund” and, together, the “Funds”), collectively referred to herein as “PSG”, “we”, “us”, and “our”, respects your concerns about privacy.
PSG is committed to safeguarding information provided to us by any third parties (“you”) (including its clients, investors and all visitors to the website psgequity.com (the “Website”)) from which any individual or household can be identified, such as names, contact details, and identification data (“Personal Information”). To the extent that any Personal Information is collected, it will be held in confidence in accordance with the Data Protection Legislation (as defined below). Please read the following Privacy and Cookies Policy (the “Policy”), which explains how we use and protect your information.
Please note that if you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to the Fund Privacy Notice (as available in [our investor portal] or otherwise provided to you) for further information about how we collect and processes personal information about our current, prospective and former investors.
We will only use Personal Information that is provided to us, or otherwise obtained by us, as set out in this Policy and, where applicable, the other privacy notices or policies provided to you or otherwise made available by us from time to time. We will ensure that your Personal Information is handled in accordance with the “Data Protection Legislation.” Data Protection Legislation means applicable law relating to the processing of Personal Information, data protection and/or privacy, including the EU General Data Protection Regulation, the Cayman Data Protection Law, 2017, and the California Consumer Privacy Act.
By visiting and/or contacting us through the Website (or otherwise engaging with us, such as for investor relations purposes), you acknowledge that we may collect, use, and transfer your Personal Information as set out in this Policy. PSG reserves the right to change this Policy from time to time, as discussed further in section 12, and you should therefore check this page frequently to ensure that you have reviewed and understand any such changes.
For the purposes of the Data Protection Legislation, PSG or any Funds in which you invest are each a “data controller”, “controller” or “business” in respect of any Personal Information that you provide to us or we otherwise obtain about you.
1. PERSONAL INFORMATION THAT WE COLLECT FROM YOU
When you (or your authorized representatives on your behalf) engage with us (e.g. by sending us emails, contacting us via telephone or visiting or making an enquiry or completing a form through the Website), we may receive Personal Information about you, including:
- Identifiers such as your name, residential and/or business address, mailing address, email address, personal and/or business contact information, tax identification number, and passport number.
- Information classified as personal or protected information by state or federal law, including your nationality, state, and/or country of domicile, place and date of birth, and correspondence records.
- Commercial information, including tax information, bank account details, source of funds details, and details related to your investment activity.
- Internet or other electronic network activity information, such as your IP address and choice of web browser and version, login data, unique device identifiers, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile device carrier and other technology on the devices you use to access the Website; as well as usage information, such as information about how you use the Website and our products and services, referring/exit web pages, date/time stamps, error logs, and the frequency of your use of the Website.
- Visual information, including your signature.
- Professional or employment-related information, including your job title, employer’s name, place of work, work history and income.
- Inferences that we draw from your personal information to create a profile about your preferences.
Some of this Personal Information is collected and processed so we can perform or take steps at your request prior to entering into a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (including to carry out and improve our business, analyze the use of our Website and services and support our staff and clients).
Where you apply for a job with us, we may collect from you and third parties (where relevant) additional Personal Information such as your CV and any references. Unless (a) you agree that we may keep such information on file for future opportunities or (b) we need to retain such information for compliance with our legal obligations, in the event that you are unsuccessful in the employment application process, we will only retain such Personal Information for as long as is reasonably necessary to process your application.
Where you provide Personal Information on behalf of other individuals, you are responsible for notifying those individuals that you have provided their Personal Information to us and directing them to this Policy so they understand how we will process their Personal Information.
We may also collect, use and share aggregated information such as statistical or demographic data for any purpose. This information could be derived from your Personal Information but will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect information with your Personal Information so that it can directly or indirectly identify you, we treat the combined information as Personal Information which will be used in accordance with this Policy.
2. PERSONAL INFORMATION THAT WE RECEIVE FROM OTHER SOURCES
We may receive information from third parties who collect Personal Information from you and pass it on to us. For example: (a) where we are conducting due diligence on prospective portfolio companies or deciding whether to invest in third parties, we may also receive Personal Information concerning key personnel; (b) our staff may give us emergency contact information as part of our emergency scenario planning and may give us details of their dependents and of other people in relation to their employee benefits arrangements; (c) where another individual makes an investment on your behalf, they may provide us with certain Personal Information to effect the transfer of the investment to you, such as your name and contact details; (d) where necessary for our or a third party’s legitimate interests, or (if required by law) where you have consented, Providence Equity Partners L.L.C. and its affiliates (collectively, “PEP”) may share your Personal Information with us, including so we can offer or market our services to you; (e) your employer may provide your Personal Information to us in connection with a service they provide to us or in connection with services that we provide to our clients; and (f) we may receive information from your past employers and others concerning your employment history when you apply for a job with us. Where this is the case, the third party is responsible for informing you that they have shared your Personal Information with us, directing you to this Policy and obtaining any relevant consents from you to ensure you have reviewed and understand the ways in which your Personal Information will be used. However, once in our possession, we will only handle any person’s Personal Information in accordance with this Policy and the other privacy notices or policies provided to you or otherwise made available by us from time to time.
3. SENSITIVE PERSONAL INFORMATION
“Sensitive Personal Information” is Personal Information concerning an individual’s (a) racial or ethnic origin; (b) political opinions; (c) religious beliefs or other beliefs of a similar nature; (d) membership of a trade union; (e) physical or mental health or condition; (f) sexual life or orientation; and (g) commission or alleged commission of any offence or any proceedings for any offense committed or alleged to have been committed by him/her, the disposal of such proceedings or the sentence of any court in such proceedings.
You may provide us with Sensitive Personal Information from time to time in connection with your application to invest with us, our provision of investment services to you, where you apply for a management role as a director of one of our portfolio companies, or otherwise. In such cases, the provision of this information is entirely voluntary and subject to your express consent; however, we may be unable to carry out certain activities necessary to process your application, instructions or other requests without the provision of such information. For example, we may be unable to process application forms or similar requests. We will use any Sensitive Personal Information in accordance with the consent you have given and, where necessary, we may also process such information in the establishment, exercise or defense of legal claims.
Where we do receive Sensitive Personal Information, we will only keep such information for as long as necessary in order to fulfil the purpose for which it was provided and to comply with our obligations under the law.
4. WHAT WE DO WITH YOUR PERSONAL INFORMATION
We will only use your Personal Information for the following legitimate business purposes:
- where necessary for us to enter into or to perform a contract with you, or to take steps at your request prior to entering into a contract – for example, to provide information you have requested or to respond to your questions, to manage and administer your investment or proposed investment in the relevant Fund and any related accounts on an ongoing basis, in accordance with the contract between you and the relevant Fund;
- where necessary for the purposes of our or other third parties’ legitimate interests, including to operate and facilitate our business and services, communicate with you and provide investor relations and support to you in respect of these services, improve the Website and our services, undertake business management, planning, statistical analysis, market research and marketing activities (including email marketing), administer and maintain our core records, protect our rights and interests, ensure the security of our assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, enforce our terms and conditions, and where relevant, provide support to our staff and our assessments of prospective investee companies where relevant, and to process your application for employment;
- where required to comply with our own legal and regulatory obligations, including in relation to financial promotion, applicable know-your-customer, anti-money laundering and counter terrorist financial legislation, the Common Reporting Standard and FATCA; and
- where necessary for the establishment, exercise or defense of legal claims.
Where you have explicitly consented at the time we collected your Personal Information or where we otherwise have a right to do so, we may also use your Personal Information to inform you of any of our services that may be of interest to you and/or inform you about important changes or developments to our services by email. To the extent permitted by law (or otherwise with your consent), we also permit authorized third parties, such as PEP to offer or market their services to you.
Where you or your employer (or any other entity you work for) provides services to us, you and/or they may provide us with some of your Personal Information, such as your name, business contact details and other identification information, in connection with the provision of such services. We will only process such Personal Information in connection with the provision of such services (such as using your contact details to discuss the services) and in accordance with this Policy. In addition, where necessary, we may also share your Personal Information with our investors or other third parties in order to provide our services (e.g. if you or your business provides investor administration services, we may share your business contact details with our investors so that they can contact you).
Should we wish to use Personal Information for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you. We will not use Personal Information for any purposes inconsistent with this Policy (and the other privacy notices or policies provided to you or otherwise made available by us from time to time) without your permission.
If you change your mind about us using your Personal Information in the ways described in this Policy, please let us know by contacting us at email@example.com.
5. HOW WE SHARE YOUR PERSONAL INFORMATION
This section 5 applies only to Personal Information collected by PSG from within the European Economic Area (the “EEA”).
Where it is necessary for the performance of our contract with you or for our or other third parties’ legitimate interests or internal business processes, we may share your Personal Information with certain third parties, such as our Funds’ professional advisors, service providers, regulatory bodies, auditors, technology providers and any duly authorized agents or related, associated or affiliated companies of the foregoing for the same purposes. We may also share your Personal Information with PEP for the purposes as further described above.
By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We take reasonable steps to ensure that third party organizations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.
It may also be necessary to disclose your Personal Information if we are under a duty to do so in order to comply with any legal obligation (such as anti-money laundering or anti-terrorist financing obligations), carry out an internal investigation, enforce the “Terms and Conditions of Use” found on our Website and the terms and conditions of any other agreement, or protect the rights, property, or safety of PSG, the Funds, our portfolio companies and our clients, directors, employees or other personnel. This includes exchanging information with other companies and organizations for the purposes of fraud protection and prevention. In particular, in order to comply with the Common Reporting Standard and FATCA, Personal Information may be shared with the tax authority of the jurisdiction in which the relevant Fund is domiciled. In turn, such tax authority may exchange information (including Personal Information and financial information) with foreign tax authorities (including the U.S. Internal Revenue Service and foreign tax authorities located outside the EEA).
We may also disclose your Personal Information as permitted by applicable law: (a) if we sell all or part of our business or make a sale or transfer of assets or if we are otherwise involved in a merger, restructuring or business transfer; or (b) as necessary for the establishment, exercise or defense of legal claims, or where otherwise necessary to protect our rights and property.
We will not sell your Personal Information.
6. OUR SECURITY MEASURES AND INFORMATION ABOUT WHEN WE DELETE DATA
We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation allows.
When deciding how long to retain Personal Information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information, the purposes for which we process Personal Information and whether we can achieve those purposes through other means. We may also retain Personal Information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
We are committed to maintaining the confidentiality, integrity and security of your Personal Information and take precautions to protect such information. These precautions include the adoption of certain physical, electronic, and procedural safeguards and procedures designed to maintain and secure your Personal Information from inappropriate disclosure in accordance with applicable laws and regulations.
Our policies require that access to personal information be restricted to those of our employees and agents who need to know that information in order to provide our services. We may disclose such information to our service providers (including financial, technical, marketing and professional service providers and consultants) and financial institutions that provide services to us. We require such third-party service providers and financial institutions to protect the confidentiality of your Personal Information and to use the information only for purposes for which it is disclosed to them.
Unfortunately, the transmission of information via the Internet is not completely secure and, although we will take steps to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted via the Website; any transmission is therefore at your own risk.
Where you have chosen a password which allows you to access certain parts of the Website, such as the section entitled “Login”, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
Some of our premises use CCTV for the purpose of crime prevention; however, this is under the control of a third party and therefore you should consult any notices they display and their privacy statements for more information.
7. TRANSFERRING PERSONAL INFORMATION OUTSIDE OF THE EEA
Any Personal Information provided to PSG will be transferred to and stored on PSG’s servers or the servers of third party service providers, which may be located in countries (including the United States) other than the one in which you reside. The European Union and United Kingdom do not consider the United States and many other countries to provide essentially equivalent privacy protections. Such transfers are a necessary part of the services that we provide and we take steps to protect your Personal Information from unauthorized access and against unlawful processing, accidental loss, destruction and damage in such circumstances.
In processing your Personal Information, it will sometimes be necessary for us to transfer Personal Information that is collected from within the EEA outside the “EEA” to our staff and our third-party service providers. It may also be accessed by staff operating outside the EEA who work for us or for one of our suppliers or group companies. This includes people engaged in, among other things, the provision of support services to us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. In order to ensure this level of protection for your Personal Information, PSG will, where appropriate, rely on appropriate or suitable safeguards in accordance with applicable Data Protection Legislation, including:
(a) where the relevant country or recipient has been deemed to provide an adequate level of protection for your Personal Information by relevant authorities;
(b) using a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission;
(c) obtaining your consent to transfer Personal Information after first informing you about the possible risks of such a transfer;
(d) transferring the Personal Information because it is necessary for the performance of (or to enter into) a contract between you and us, or because the transfer is necessary for the performance of a contract between us and a third party, and the contract was entered into in your interest; and
(e) transferring the personal information because it is necessary to establish, exercise or defend legal claims.
For the avoidance of doubt, in the event that the United Kingdom (the “UK”) is no longer a part of the EEA, references in the paragraph above to the EEA shall mean the EEA and the UK.
By submitting your Personal Information to us, you acknowledge this may involve the transfer, storing or processing of your Personal Information.
8. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
Individuals in Andorra, Argentina, Australia, California, Canada, Cayman Islands, the European Economic Area, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include, subject to certain limitations, the right for individuals to: (i) request access to and rectification or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection or supervisory authority.
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.
To exercise any of these rights, please contact us by calling 1-877-312-3035 or emailing firstname.lastname@example.org.
Depending on your jurisdiction, you may also be entitled to direct any complaints in relation to our processing of Personal Information to your national or local data protection or supervisory authority.
Individuals who submit requests for access or erasure of personal information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until such individual’s identity is verified.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.
We will not discriminate against you based on the exercise of your privacy rights.
We take very seriously any complaints we receive about our use of Personal Information. Should you have any queries or complaints in relation to how we use your Personal Information, please contact us at email@example.com.
10. THIRD PARTY LINKS
Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any Personal Information via these websites.
A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the Personal Information you choose to share with us (including Personal Information you automatically share with us by way of your browser settings). In particular, we use the following cookies:
(a) Performance cookies. These cookies collect information about how visitors use our Website, for instance which pages visitors go to most often and if they get error messages from the web pages. These cookies don’t collect information that identifies a visitor; all information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our Website works.
(b) Session cookies. These cookies allow us to identify your device as you use the Website, so that you are not treated as a new visitor each time you go to another part of the Website.
We may use third-party web analytics services (such as those of Google Analytics) and other technologies on the Website to collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you can install the Google Analytics Opt-out Browser Add-on by clicking here.
You will normally see a message on our Website before we store a cookie on your computer which describes the types of cookies we use and what information they might collect. We may also use banners and pop-ups from time to time to give you options around cookie use.
You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our Website.
You can find more information about the specific cookies we use and the purposes for which we use them in Appendix 1 of this Policy. You can find more information about cookies generally here: www.allaboutcookies.org.
12. CHANGES TO THIS PRIVACY AND COOKIES POLICY
PSG may amend this Policy at any time without notice. In the event any such amendments are made, PSG will post the updated Policy to the Website. By continuing to use the Website and making use of our services you acknowledge that we shall process your Personal Information in accordance with the updated Policy. If you are not comfortable with the updated Policy, you should not use or access (or continue to use or access) the Website and/or our services.
13. CHILDREN’S PRIVACY
We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Our services are not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target children under the age of 13.
14. OUR CONTACT INFORMATION
If you have any questions (including relating to transfers of your Personal Information outside the EEA), please feel free to contact us by email at: firstname.lastname@example.org.
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