Privacy and Cookies Policy

Providence Equity Partners L.L.C. (a limited liability company incorporated in Delaware, USA), together with its associated offices practicing under the “Providence Equity” name in other jurisdictions including Providence Equity LLP (a limited liability partnership incorporated in England and Wales), its affiliated investment advisers including Providence Strategic Growth Capital Partners L.L.C. (a limited liability company incorporated in Delaware, USA) and the funds which it manages (each a “Fund” and, together, the “Funds”), collectively referred to herein as “Providence”, “we”, “us”, and “our”, respects your concerns about privacy.

Providence is committed to safeguarding information provided to us by any third parties (“you”) (including its clients, investors and all visitors to the website www.provequity.com (the “Website”)) from which any individual 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.

We will only use Personal Information that is provided to us, or otherwise obtained by us, as set out in this Policy. 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law relating to the processing of Personal Information and/or privacy as the same may be re-enacted, applied, amended, superseded, repealed, or consolidated, including without limitation, the EU General Data Protection Regulation“”, the Cayman Data Protection Law, 2017“”, and the California Consumer Privacy Act“”, in each case including any legally binding regulations, directions, and orders issued under or in connection with any such law).

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. Providence reserves the right to change this Policy from time to time, as discussed further in section 11, 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, Providence or any Funds in which you invest are each a “business” or “data controller” 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 engage with us (e.g. by sending us emails, contacting us via telephone or visiting or making an enquiry through the Website), you may provide Personal Information about yourself, 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.
  • Visual information, including your signature.
  • Professional or employment-related information, including your employment, employer’s name, 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 a contract with you, some for the purpose of legal compliance and some for the purposes of our legitimate business interests (namely 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.

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) 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 (e) 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.

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; (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:

  • 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;
  • to provide investor relations and support to you in respect of these services;
  • to improve our Website and services;
  • to comply with our own legal and regulatory obligations, including in relation to financial promotion, applicable anti-money laundering and counter terrorist financial legislation, the Common Reporting Standard and FATCA;
  • for our internal business processes, including providing support to our staff and our assessments of prospective investee companies; and
  • where relevant, to process your application for employment.

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.

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).

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 privacy@provequity.com.

5. HOW WE SHARE YOUR PERSONAL INFORMATION

This section 5 applies only to Personal Information collected by Providence Equity Partners LLP or to Personal Information collected by Providence from within the EEA.

Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties, such as our Funds’ administrator and other delegates, 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.

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 Providence, 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).

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.

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.

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.

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 Providence will be transferred to and stored on Providence’s servers or the servers of third party service providers, which may be located outside of the EEA, including in the United States. We take steps to protect your Personal Information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.

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, Providence will, where appropriate, use a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. For the avoidance of doubt, in the event that the UK is no longer a part of the EEA, references in this paragraph 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, Europe, 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 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 privacy@provequity.com.

Depending on your jurisdiction, you may also be entitled to direct any complaints in relation to our processing of Investor Data to your national or local data protection 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.

9. COMPLAINTS

Should you have any queries or complaints in relation to how we use your Personal Information, please contact us at privacy@provequity.com. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner’s Office regarding such issues.

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.

10. OUR USE OF COOKIES

A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyze web traffic and identify which pages of our Website are being used. Our Website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences as well as enabling you to login to and use the section entitled “Login”. We only use this information for statistical analysis purposes and it is removed from our systems at the expiry of the duration period set out in Appendix 1 of this Policy.

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.

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.

11. CHANGES TO THIS PRIVACY AND COOKIES POLICY

Providence may amend this Policy at any time without notice. In the event any such amendments are made, Providence 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.

12. 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.

13. 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: privacy@provequity.com.

APPENDIX 1

Cookie Name Host Description Duration
Performance cookies
Google Analytics
(_ga, _gat* and _gid)
www.provequity.com Cookies for Google Analytics to function _ga – 1 year
_gid – 24 hours
_gat* - 1 hour
Session cookies
_providence_session and request_method www.provequity.com Built in Rails session. Used to track CMS logins session