OUR COMMITMENT TO PRIVACY
Visitors who are residents of the United Kingdom, the European Union or the European Economic Area should refer to our EU Privacy Notice supplement.
Your privacy is important to Steinbeck Investment Company and its affiliates (together, “Steinbeck,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
THE INFORMATION WE COLLECT AND HOW WE USE IT
We may collect various types of information from users of this website. Steinbeck generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact Us” page.
The transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
You represent to Steinbeck that you have the authority to visit this website. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
This website uses Google Analytics, which collects information on site visitors and usage through cookies. (For more information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners). By using the site you hereby understand and consent to Google’s collection and processing of any data submitted by you to Steinbeck (including personally identifiable information such as IP address, domain name, webpage, the length of time spent on the site, or the pages accessed while visiting the site).
NOTIFICATION OF CHANGES
The provisions in our Terms and Conditions are hereby incorporated by reference.
Date: January 2021
What information do we collect about you?
We collect limited types of personal information through our website and investor reporting portals as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depend 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:
We do not knowingly collect or solicit personal information from anyone under the age of 18.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
We may combine personal information 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.
How do we use your personal information?
We will use your personal information for one or more of the following business purposes:
Additionally, we may use your personal 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 maybe interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.
Who do we share your personal information with?
We do not sell any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them. We may also disclose your information to other parties as maybe required by law or regulation, or in response to regulatory inquiries.
Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “What information do we collect about you?”
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.
How do we keep your personal information secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
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 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.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
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.
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 or your investor portal access credentials, if applicable, 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.
OUR COMMITMENT TO PRIVACY
Your privacy is important to Steinbeck Private Equity Partners, LP and its affiliates (together, “Steinbeck,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
We rely on various legal bases under applicable data protection legislation in order to process your personal information (e.g., name, title, address, email, date of birth, IP address, financial data, username, password, etc.), including our legitimate interests, contractual necessity and as required by law. We use the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal information about you (this 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). Nor do we collect any information about criminal convictions and offences.
If we require your personal information 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. 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.
Further information about the legal bases under which we process your personal information is included in the section headed “Why we use your personal information.”
HOW WE OBTAIN YOUR PERSONAL INFORMATION
Information you provide to us
We collect your personal information when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal information via online form, email, post, telephone and this website and when you log into the investor online portal. We also collect information about you through automated technology.
Information provided by third parties or publicly available sources
We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).
WHY WE USE YOUR PERSONAL INFORMATION
To the extent that you provide us with any personal information, through or in connection with this website (i.e., via online form, telephone, email or post) or the investor online portal, we may use such information for the following purposes:
No automated decision-making, including profiling, is used when processing your personal information.
We may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested.
You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by contacting us at 646-598-9221. You can also click on the “opt-out”/unsubscribe link provided in our marketing emails, if applicable, or by contacting us at 646-598-9221.
DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION
The transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this website; any transmission of information or data by you to or through this website is at your sole risk.
Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by any of the foregoing. We seek assurances that our standards for data security are met by anyone who enters into an agreement providing a service to, or for us, involving personal data. To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards/derogations used, please contact us at (646) 598-9221 .
We reserve the right to disclose your personal information 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, for the purposes of public importance 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 information to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL INFORMATION
We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. 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 personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact us at (646) 598-9221 .
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (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.
NOTIFICATION OF CHANGES
Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.