Privacy Policy

At Waterton Associates L.L.C. and its respective subsidiaries and affiliates (collectively, “Waterton”, “we”, “us” and “our”), we are committed to maintaining the confidentiality of your personal and financial information. The purpose of this website privacy policy (this “Privacy Policy”) is to explain the types of Personally Identifiable Information or Non-Personally Identifiable Information Waterton collects through the Waterton Associates website located at https://www.waterton.com, our investor reporting portals and related websites or portals, as well as through other electronic communications (e.g., emails) as applicable (collectively, our “Sites”), how the information is obtained, how it is used, and the choices you have regarding our use of, and your ability to review and correct, the information.

This Privacy Policy applies solely to your interactions with us through our Sites. If you provide personal information to us through another means (e.g., as a client, or as an investor in one of Waterton Associates’ funds) you will receive a separate privacy notice and that notice will govern that personal information.

WHAT INFORMATION WE COLLECT

The information we collect in our business and on our Sites generally falls into the following two categories: Personally Identifiable Information and Non-Personally Identifiable Information.

Personally Identifiable Information: This refers to information that lets us know the specifics of who you are or enables us to identify you personally and is deemed to include personal information collected by Waterton through the Sites. The categories of Personally Identifiable Information we may have collected from individuals on the Sites in the last twelve (12) months include the following:

  • Identifiers, such as your name, contact details and address (including physical address, email address and Internet Protocol (“IP”) address). This information may be provided when you contact us via the “Contact Us” page on our Sites or when you otherwise contact us;
  • Other customer records, such as telephone number and Personally Identifiable Information provided in connection with obtaining account access;
  • Commercial information such as account data;
  • Professional or employment-related information;
  • Educational information; and/or
  • Internet or other electronic network activity information, such as information regarding your use our Sites (e.g., browsing history and/or search history), as well as the browser, device, your IP address, access times, operating system and platform, and other information gathered via cookies employed on our Sites, as well as information you provide to us when you correspond with us in relation to inquiries.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

Non-Personally Identifiable Information: This refers to information that does not and cannot reasonably be used to identify a specific individual. The non-personally identifiable data we collect through the Sites may include aggregated statistical data or data not attributable to a specific person or entity. Non-personally Identifiable Information we collect when you visit our Sites may include the Uniform Resource Locator (“URL”) of the web site that you came from before visiting our Sites, which pages you visit on our Sites, which URL you go to next, which browser you used to come to our Sites, and any search terms entered on our Sites. This Privacy Policy also contains more information about how we use cookies and other technology to collect this data.

We do not connect or cross-reference the Personally Identifiable Information and Non-Personally Identifiable Information we collect in our business or on our Sites.

WHY WE COLLECT INFORMATION ABOUT YOU

Our primary goals in collecting information are to provide clients with superior service and to provide all individuals a smooth, efficient, and personalized experience.

HOW WE COLLECT INFORMATION

We may request Personally Identifiable Information when you request information or correspond with us through our Sites, including by providing information through online forms. We also collect information about you that is captured via cookies.

We only collect the information reasonably necessary to carry out our business for the purposes set out below. You can provide us with Personally Identifiable Information via the Sites, email, mail, and telephone. The types of Personally Identifiable Information we collect about you depends on the nature of your interaction with us. We also collect information about you through automated technology. We may combine Personally Identifiable Information that you provide to us with information that we collect from, or about you from publicly available sources or using automated technology. This will include information collected in an online or offline context.

Our Sites may automatically recognize a visitor’s domain name (such as .com, .edu, etc.), the web page from which a visitor enters our Sites, which pages a visitor visits on our Sites, and on some Sites, how much time a visitor spends on each page. This information does not reveal a visitor’s identity. We aggregate this information and use it to evaluate and improve our Sites. We do not monitor or profile visitors to our Sites or collect, in any automated manner, any special categories of sensitive Personally Identifiable Information about you (for example, your religious or philosophical beliefs, information about your health and genetic and biometric data, or any information about criminal convictions and offenses.)  No automated decision-making, including profiling, is used when processing your Personally Identifiable Information.

Whether you choose to provide specific information requested by Waterton is completely your own choice. But if you choose not to provide the information we request, you may be unable to receive or access certain services, offers, and information.

USING INFORMATION ABOUT YOU

Waterton does not sell or share customer information to marketers outside of our companies, without your consent.

We may share your Personally Identifiable Information with others only in certain limited situations or as otherwise agreed by you, including:

  • within our corporate group or among our affiliated entities, all of which follow this Privacy Policy or equivalent privacy policies;
  • with our service providers, including administrators, professional advisors, lenders, banks, auditors, law firms, governmental agencies, self-regulatory organizations, consultants, placement agents, insurers, technical service providers, and other third parties or other parties who are bound by contract to keep the information confidential and use it only on behalf of Waterton;
  • to communicate with you, including responding to requests for submitted by you through our Sites;
  • for business development and general marketing purposes;
  • to build relationships;
  • to satisfy contractual requirements;
  • to perform services for you;
  • to improve our Sites and the products and services that we offer and notifying you about changes to the same;
  • to keep a record of your relationship with us;
  • for ongoing operations, administrative, accounting, reporting, account maintenance, or other similar processes;
  • to audit and verify the quality and effectiveness of our services and compliance;
  • to detect and respond to security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity; and
  • to comply with applicable laws, rules, and regulations.

In some cases, we may be required to disclose certain information to comply with the law, an investigation or a legal process, such as a court order or subpoena. We may disclose information when we believe that such disclosure is reasonably necessary to enforce or protect our rights.

We may disclose aggregated information that does not identify any individual, without restriction.

Additionally, we may use your Personally Identifiable Information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested.

Within the last twelve (12) months, we have shared each of the categories of Personally Identifiable Information collected in connection with the Sites with affiliates and service providers as set forth above in “What Information We Collect”. We may have also disclosed your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

COOKIES AND OTHER TECHNOLOGY ON OUR SITES

Our Sites use “cookies” (a small text file placed on your hard drive after you visit our Sites) and other technology to enhance your online experience and to learn about how you use the Sites for purposes of improving the quality of services. Information regarding how you access the Sites (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies or other technologies or tools. 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 the Sites. You may wish to visit www.aboutcookies.org, which contains comprehensive information about different types of cookies, how they are used and how you manage your cookie preferences.

This Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to better assist Company in understanding how the Site is used. Google Analytics will place cookies on your computer that will generate information that we select about your use of the Site, including your computer’s IP address. That information will be transmitted to and stored by Google. The information will be used for the purpose of evaluating consumer use of the Site, compiling reports on Site activity for Company’s use, and providing other services relating to Site activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on such entity’s behalf. The use of cookies by Google Analytics is covered by Google’s privacy policy: https://www.google.com/policies/privacy/

PROTECTING YOUR INFORMATION

Our policy is to restrict access to your Personally Identifiable Information to only those employees, service providers (including administrators, professional advisors, lenders, banks, auditors, law firms, consultants, placement agents, insurers, and technical service providers), and other third parties who need to know that information to provide products or services to you. We maintain commercially reasonable physical, technical and procedural safeguards and maintain other applicable standards as required by law, in order to protect your Personally Identifiable Information in our possession or under our control to the extent possible from unauthorized access and improper use. We also train and instruct our employees that all Personally Identifiable Information must be handled in accordance with this Privacy Policy and applicable privacy and data protection laws, and any misuse by employees is subject to disciplinary action.

We will keep your Personally Identifiable Information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we reasonably need for those purposes. To determine the appropriate retention period for Personally Identifiable Information, we consider the amount, nature, and sensitivity of the Personally Identifiable Information, the potential risk of harm from unauthorized use or disclosure of your Personally Identifiable Information, the purposes for which we process your Personally Identifiable Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

LINKS TO THIRD PARTY SITES

Our Sites may contain links to Web sites operated and maintained by third parties, over which we have no control. Privacy policies on such linked sites may be different from our Privacy Policy. You access such linked sites at your own risk. You should always read the Privacy Policy of a linked site before disclosing any personal information on such site.

POLICY CHANGES

To improve the services we can offer you, Waterton may opt to expand our capabilities for obtaining information about users in the future. Waterton will update this privacy statement continually to ensure that you are aware of developments in this area.

We will post those changes here so that you will always know what information we collect online, how we use it, and what choices you have. Please be sure to check this page before proceeding to use our Sites. Regardless of any changes we make to our Privacy Policy, we will always use your Personally Identifiable Information in accordance with the version of the Privacy Policy in place at the time you provided your information, unless you give your express consent for us to do otherwise.

ADDITIONAL PRIVACY TERMS

In conducting business with Waterton or using the Sites, you may be required to agree to additional written or electronic agreements, including additional privacy terms and conditions (‘Additional Privacy Terms’), as a condition of visiting the Sites, or receiving products, services, and other information. In the event of any conflict between the Additional Privacy Terms and this Privacy Policy, the Additional Privacy Terms shall prevail.

BUSINESS TRANSFERS

As Waterton continues to develop the business, we may sell or buy entities, subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets. Such information remains subject to any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). In the event that Waterton is acquired in whole or in part, Personally Identifiable Information may be one of the transferred assets.

STATE OF CALIFORNIA RESIDENTS

If you are a resident of California, you also have the following rights with respect to your Personally Identifiable Information under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”):

Deletion Rights: You have the right to request that we delete any of your Personally Identifiable Information that we retain, subject to certain statutory exceptions, including our compliance with applicable 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 and use of Personally Identifiable Information specific to you over the last twelve (12) months. Such information includes:

  • the categories of Personally Identifiable Information we collected about you;
  • the categories of sources from which the Personally Identifiable Information is collected;
  • our business or commercial purpose for collecting such Personally Identifiable Information;
  • the categories of third parties with whom we share the Personally Identifiable Information;
  • the specific pieces of Personally Identifiable Information we have collected about you; and
  • whether we disclosed your Personally Identifiable Information to a third party, and if yes, the categories of Personally Identifiable Information that each recipient obtained.

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 notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the “Contact Us” section below.

CONTACT US/YOUR FEEDBACK

For any requests relating to the exercise of your rights with respect to your Personally Identifiable Information outlined above, or questions regarding our processing of your personal information or this Privacy Policy, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: 1 (833) 904-0878

Submit a request online using the following email address: CCPArequests@waterton.com.

We may need to request additional information from you in order to verify your request, including to help us confirm your identity and ensure your right to access your Personally Identifiable Information (or to exercise any of your other rights). This is a security measure to ensure that Personally Identifiable Information 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.

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 or your investor portal access credentials, if applicable, in order to verify your request. We may also verify your request through a third party verification service.

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.

Our goal is to respond to any verifiable consumer request promptly.

To help us improve our Privacy Policy and practice, please give us your feedback utilizing the “Contact us” tab.

Legal Disclaimer: This is neither an offer to sell nor a solicitation of an offer to buy the securities herein. Offerings are made only by means of a prospectus or other offering materials. This material must be preceded or accompanied by a prospectus or other offering materials. This information may not be redistributed, copied or modified in any form without prior written consent from Waterton.