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.
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:
- 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
PROTECTING YOUR INFORMATION
LINKS TO THIRD PARTY SITES
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.
ADDITIONAL PRIVACY TERMS
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
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.
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.