General Privacy Notice
ONE EQUITY PARTNERS WEBSITE PRIVACY NOTICE
OUR COMMITMENT TO PRIVACY
Your privacy is important to OEP Capital Advisors L.P., One Equity Partners Europe GmbH, OEP Italy S.R.L. and OEP Master B.V and our affiliates (together, “OEP”, “our”, “us”, “we” or “company”). To better protect your privacy, we are providing information explaining our data processing practices.
This Privacy Notice (the “Notice”), which is supplemented by the EU-UK Privacy Notice and California Privacy Notice (each, a “Jurisdiction-specific Notice”), as applicable, describes (i) how OEP Capital Advisors L.P. collects and processes personal data, personally identifiable information, personal information or other similar terms (referred to in this Notice as “personal data”) about you as a visitor of this website (which is controlled and operated by OEP Capital Advisors L.P.) or any other websites that it controls and where this Notice is posted (the “Website”) and (ii) how we collect and process personal data in relation to any other contact or communication between you and us. Please read this Notice carefully.
This Notice and the Jurisdiction-Specific Notices operate in addition to, and does not form a part of, the general Terms of Use of the Website, which can be found here. This Notice, and the Jurisdiction-Specific Notices, do not apply to any processing of personal data by or on behalf of OEP that is covered by a more specific privacy notice (including, but not limited to, our Investor Privacy Notice applicable to OEP Capital Advisors, L.P. and other investor privacy notices as applicable, our Privacy Notice for Suppliers, Customers, Service Providers and other Business Partners of One Equity Partners Europe GmbH here, our Privacy Notice for Suppliers, Customers, Service Providers, Consultants, Investors and other Business Partners of OEP Italy S.R.L. here, our Privacy Notice for Suppliers, Customers, Service Providers, Consultants, Investors and other Business Partners of OEP Master B.V. here, any employee privacy notice or any separate job applicant privacy notice) nor does this Notice or any of the Jurisdiction-Specific Notices apply to the privacy practices of other companies, entities or persons (including, as applicable, our portfolio companies).
You do not need to take any action as a result of this Notice, but you do have certain rights as described below in the section Your Rights. If you have any questions regarding our use of your personal data, or this Notice, please contact Dora Stojka at privacy@oneequity.com.
1. WHO THIS NOTICE AND THE JURISDICTION-SPECIFIC NOTICES APPLY TO
This Notice describes how we (or our service providers) gather and use personal data that we collect:
- when you use the Website;
- when you communicate with us offline and online (including via email correspondence);
- when you contact or request information from us, including through the “Contact” page on the Website;
- when you are generally seeking to engage our services or solicit our business as a customer of ours;
- when you are a manager, adviser or shareholder of one of our portfolio companies (or of a prospective portfolio company);
- when you contact us directly via one of our members of staff or via an introduction from anyone with whom we have an existing business relationship; and/or
- through other data collection points where we refer to this Notice.
We may combine personal data that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
If you are located in the European Union, European Economic Area or the United Kingdom, or if the processing of your personal data would otherwise be subject to EU and/or UK data protection laws, please also read our EU-UK Privacy Notice.
If you are a resident of California, please also read our California Privacy Notice.
This Notice is supplemented by the Jurisdiction-Specific Notices, each of which forms part of this Notice and in the event of a conflict between any such supplement and the Notice, the applicable supplement shall take precedence.
2. WHAT PERSONAL DATA WE MAY COLLECT ABOUT YOU
We or our service providers may collect some or all of the following personal data about you for one or more purposes set out in this Notice, depending on the nature of our relationship or interactions with you:
- Your basic information: such as your name, prefix/title, gender, age and/or date of birth.
- Contact information: such as physical address, telephone number and/or email address.
- Information we obtain by automated means: such as information about your computer / device and IP address, content and traffic data. OEP Capital Advisors L.P. may also collect personal data about you through automated technology when you access and use our Website, such as cookies and similar technology (please see the “Cookies” section below for information about OEP Capital Advisor L.P. uses such technologies).
- Information obtained through communications with us: such as information obtained through telephone calls (which may be recorded for compliance purposes), emails, video communications and other verbal communications, and written correspondence.
- CV information: such as education history, employment history, job title and other information about your qualifications, only where you are applying for a job with us.
- Other information: such as information provided by third parties or obtained through publicly available sources.
Please also refer to the Jurisdiction-Specific Notices for further information about what personal data we may collect.
3. HOW AND WHY WE USE YOUR PERSONAL DATA
To the extent that you provide us with, or we otherwise collect, any personal data, through or in connection with this Website or any other contact or correspondence between you and us (i.e., whether online, or via telephone, email or post), we may use such personal data for the following purposes:
| Purpose | Legal Basis to Process Personal Data, to the Extent Collected Under EU and UK Privacy Laws |
|---|---|
| To conduct business with you or to provide you with the services or financial products you have requested. | Contractual necessity; and/or our legitimate interest in operating our business |
| To respond to your enquiries and requests and provideing you support. | Contractual necessity and/or our legitimate interest in operating our business |
| To communicate with you, to operate, schedule and facilitate meetings (in-person and online) and to administer your participation in any of our events. | Our legitimate interest in operating our business and providing investment services and/or consent |
| To consider job candidates for our existing and potential recruitment needs and those of our portfolio companies whether in respect of permanent roles or temporary assignments. | Our (or our portfolio companies’) legitimate interest in operating our (or their) business and/or consent |
| For account administration purposes. | Legal requirement; our legitimate interest in operating our business; and/or consent |
| To keep a record of your relationship with us. | Our legitimate interest in operating our business |
| To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to. | Our legitimate interest in operating our business; contractual necessity; and/or legal requirement |
| To monitor and manage our portfolio companies. | Our legitimate interest in operating our business and/or contractual necessity |
| Fraud and abuse prevention, and to protect against identify and prevent cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website, investor portals, products and services, databases, technology assets or our business, and other malicious, or unlawful activity. | Legal requirement; our legitimate interest in operating our business and providing services securely and safely; and/or consent |
| Complying with our legal obligations and corporate governance practices including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations, which may require recording or monitoring telephone calls or other communications with you. | Legal requirement; our legitimate interest in operating our business |
| Litigation management and conducting internal audits and investigations. | Legal requirement; and/or our legitimate interest in operating our business |
| To obtain advice from our professional advisors, including lawyers and accountants. | Our legitimate interest in operating our business |
| To administer and protect our business and this Website. | Our legitimate interest in operating our business and/or consent |
| To make suggestions and recommendations to you about goods or services that may be of interest to you. | Our legitimate interest in operating our business |
| For performance of IT systems. | Our legitimate interest in operating our business |
| For any other purpose that has been notified, or has been agreed, in writing. | As shown in such notice, as applicable |
Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the initial purpose. We will notify you and explain the legal basis which allows us to do so if we need to use your personal data for an unrelated purpose.
No automated decision making, including profiling, is used when processing your personal data.
4. DISCLOSURE AND TRANSFER OF PERSONAL DATA
Your personal data may be disclosed to and processed by our affiliates and agents and certain service providers as necessary to fulfil the purposes set out in this Notice, including professional advisors, recruitment firms, consultants and data hosting providers, as well as regulators, law enforcement and other government bodies. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.
We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.
The Website contains links to other websites which are not hosted or operated by us. These websites may use automated means to collect information regarding your use of the websites. This information is subject to the privacy policies or notices of the provider’s website.
5. SECURITY AND RETENTION OF PERSONAL DATA
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the personal data we have about you is protected appropriately from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. To the extent legally required, they will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Although we take reasonable precautions to protect your personal data, there remains a risk that personal data transmitted over the internet and stored digitally may be intercepted or accessed by an unauthorised third party. As such, any transmission of personal data by you to or through the Website is at your sole risk.
We review the personal data we hold on a periodic basis and delete it securely. We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Notice, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact privacy@oneequity.com.
6. CAPACITY
This Website is only intended for individuals who are at least 8 years of age. OEP Capital Advisors L.P. does not knowingly encourage or solicit visitors to this Website who are under the age of 8 or knowingly collects personal data from anyone under the age of 8 without parental consent. If OEP Capital Advisors L.P. learns it has collected or received personal data from an individual under the age of 8, it will delete that personal data.
7. COOKIES
Information regarding how you access this Website (e.g., browser type, access times, and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for OEP Capital Advisors L.P. to provide the products or services you have requested or for the functioning of this Website, OEP Capital Advisors L.P. will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this Website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.
The www.oneequity.com website currently uses the following cookies:
Subject to your consent, the Website will place the cookies listed below:
| Cookie name | Source | Purpose | Type | Duration |
|---|---|---|---|---|
| _ga | Google Analytics (GA) | Allows GA to track distinguish users and track page views. GA does not track or collect personally identifiable information. | Analytics | 2 years |
| _ga_*_ | Google Analytics (GA) | Allows GA to persist session state. | Analytics | 2 years |
| Cookie-policy | OEP website | Tracks visitor cookies policy acceptance. | Functional | 1 month |
| vuid | Vimeo | Vimeo-generated ID used for generating analytics information for the video owner. | Analytics | 2 years |
| player | Vimeo | Stores preferences for player controls (i.e. volume, stream quality, captions). | Functional | 1 year |
| _cf_bm | Vimeo | Cloudflare bot manager, manages incoming traffic that matches criteria associated with bots. | Functional | 30 minutes |
| _cfvuid | Vimeo | Cloudflare cookie used to enforce rate limiting rules. | Functional | Session |
8. YOUR RIGHTS
Under certain circumstances, by law you have the right to access and control, in certain ways, the personal data we hold about you. Please refer to the EU-UK Privacy Notice and California Privacy Notice (as applicable) for more specific information about your rights. If you would like more information about your rights, or have concerns about OEP’s processing of your personal data, please contact privacy@oneequity.com.
9. NOTIFICATION OF CHANGES
We reserve the right to amend this Notice from time to time by updating this Notice. If we decide to change our Notice, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use personal data only in accordance with this Notice or any other privacy notice under which the personal data was collected.
10. CONTACT US
If you have any questions or concerns about this Notice, or wish to exercise any rights, submit requests, or appeal any of our decisions in connection with this Privacy Notice (each, a “Communication”), or to view this Privacy Notice in an alternate format please contact privacy@oneequity.com.
We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information in order to verify your Communication.
Updated August 2024
EU-UK PRIVACY NOTICE
This EU-UK Privacy Notice supplements the Notice with respect to additional information as required by applicable EU and UK data protection laws, including (without limitation) Regulation (EU) 2016/679 (the “EU GDPR”), the UK equivalent of the EU GDPR (the “UK GDPR”) and the Data Protection Act 2018 (the “EU and UK Privacy Laws”). For the purposes of applicable EU and UK Privacy Laws, each OEP entity will be the data controller for its respective processing of your personal data in the ways described above (e.g., when you visit the Website the data is collected and processed as described above by OEP Capital Advisors L.P. which therefore is the controller for that processing).
1. ADDITIONAL INFORMATION ABOUT THE PERSONAL DATA WE MAY COLLECT
We do not collect any information about criminal convictions and offenses, or any special category personal data (which includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, note that there may be limited circumstances where we need to collect this type of personal data or it is otherwise collected incidentally (e.g., via use of security camera systems).
2. ADDITIONAL INFORMATION ABOUT THE LEGAL BASES WE MAY RELY UPON
We rely on various legal bases under applicable EU and UK Privacy Laws in order to process your personal data, as set out above in the Notice in section How and Why We Use Your Personal Data. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations and failure to provide this information means that we cannot provide our services or products to you). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. TRANSFERS OF PERSONAL DATA
We may store your personal data electronically or in physical form. Your personal data may be transferred to and stored at, a destination outside the UK, EU or European Economic Area (“EEA”) which may not always have data protection laws providing equivalent protection. To the extent your personal data is transferred to countries outside of the UK, EU or EEA, such transfers will only be made in accordance with EU and UK Privacy Laws, as applicable. For further information about the safeguards used, please contact privacy@oneequity.com.
4. YOUR RIGHTS
Under certain circumstances, by law you have the right to access personal data we maintain about you, and there are several ways you can control the way in which and what personal data we process about you.
- Access: You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to such your personal data if it is inaccurate or it needs to be updated.
- Deletion: If you think that we shouldn’t be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer your personal data to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
- Lodge a complaint: You have a right to lodge a complaint to your local supervisory authority (as discussed below) if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal data.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Please note that the various rights listed above are not absolute, are subject to certain exceptions or qualifications and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.
To exercise these rights, please contact us at privacy@oneequity.com. We will respond to your request within one month of receipt of your request. In some cases we may not be able to fulfillfulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
Should you wish to lodge a complaint with regards to how your personal data has been processed by us under:
- the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office at https://ico.org.uk/global/contact-us; or
- the EU GDPR, please contact your local supervisory authority.
- We would, however, appreciate the opportunity to address your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.
5. CONTACT US
If you have any questions or requests regarding this EU-UK Privacy Notice, please contact privacy@oneequity.com.
The following companies are your “controllers” for their respective processing activities to the extent they process your personal data and are therefore responsible for the collection, use, disclosure, retention and protection of your personal data in accordance with the EU and UK Privacy Laws:
One Equity Partners Europe GmbH
Neue Mainzer Str. 84, 60311
Frankfurt am Main, Germany
OEP Italy S.R.L.
Via Alessandro Manzoni 38
20121 Milano
Italy
OEP Master B.V
2Amsterdam – Eduard van Beinumstraat 30
1077 CZ Amsterdam
The Netherlands
OEP Capital Advisors L.P.
330 N. Wabash Ave., Suite 3750
Chicago, IL 60611
United States of America
Updated [●] August 2024
CALIFORNIA PRIVACY NOTICE
This California Privacy Notice (the “California Privacy Notice”) supplements the Privacy Notice with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, and together with its implementing regulations and guidelines, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
What does this California Privacy Notice apply to?
This California Privacy Notice applies to your interactions with us:
- when you use the Website;
- when you communicate with us offline and online (including emails);
- when you contact or request information from us, including through the “Contact” page on the Website;
- when you are generally seeking to engage our services or solicit our business as a customer of ours;
- when you are a manager, adviser or shareholder of one of our portfolio companies (or of a prospective portfolio company);
- when you contact us directly via one of our members of staff or via an introduction from anyone with whom we have an existing business relationship;
- when you visit our offices;
- when you apply for a job with us; and/or
- through other data collection points where we refer to this California Privacy Notice.
What Categories of Information Do We Collect About You?
The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information). | YES |
| C. Protected classification characteristics under California or federal law | Date of birth, citizenship and birthplace. | NO |
| D. Commercial information | Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). | NO |
| E. Biometric information | Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. | NO |
| F. Internet or other similar network activity | Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries | YES |
| G. Geolocation data | Physical location or movements. | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information (see further information on use of sensitive personal information below) | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. | YES, as to the following types of information: social security, driver’s license, state identification card, or passport numbers; account log-in, financial account in combination with any required security or access code password; or credentials allowing access to an account only. |
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business;
- To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
We collect personal information for the business or commercial purposes and from the sources set forth “__What Personal Data We Collect and How We Collect Personal Data?”, respectively, in the Privacy Notice above. We retain the categories of personal information set forth above in “How do we collect personal data?__” section of this California Privacy Notice only as long as is reasonably necessary for those purposes set forth in [“How and Why We Use Your Personal Information”](# in the Privacy Notice above, except as may be required under applicable law, court order or government regulations.
To Whom Do We Disclose Your Personal Information?
We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
| Personal Information Category | Category of Third-Party Recipients |
|---|---|
| A. Identifiers | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| C. Protected classification characteristics under California or federal law | N/A |
| D. Commercial Information | N/A |
| E. Biometric Information | N/A |
| F. Internet or other similar network activity | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| G. Geolocation data | N/A |
| H. Sensory data | N/A |
| I. Professional or employment-related data | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | N/A |
| K. Inferences drawn from other personal information | N/A |
| L. Sensitive Personal Information | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
We take measures to protect your personal information as set forth in “Security and Retention of Personal Information” in the Privacy Notice above.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:
- The categories of personal information we collected about you;
- The categories of sources from which the personal information is collected;
- Our business or commercial purpose for collecting such personal information;
- Categories of third parties to whom we disclose the personal information;
- The specific pieces of personal information we have collected about you; and
- Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this California Privacy Notice in an alternative format, please submit a request on your behalf using any of the methods set forth below.
[If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at privacy@oneequity.com, and we will call you during business hours.]
You can also email us at the following email address: privacy@oneequity.com.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Please contact privacy@oneequity.com with any questions about this California Privacy Notice.
