\n| L. Sensitive Personal Information<\/td>\n | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n How do we keep your personal information secure?<\/strong><\/p>\nWe consider the protection of personal 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.<\/p>\n Your rights under the CCPA<\/strong><\/p>\nDeletion Rights<\/u><\/em>: 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.<\/p>\nDisclosure and Access Rights<\/u><\/em>: 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:<\/p>\n\n- the categories of personal information we collected about you;<\/li>\n
- the categories of sources from which the personal information is collected;<\/li>\n
- our business or commercial purpose for collecting such personal information;<\/li>\n
- the categories of third parties with whom we disclose the personal information;<\/li>\n
- the specific pieces of personal information we have collected about you; and<\/li>\n
- whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.<\/li>\n<\/ul>\n
Correction Right<\/u><\/em>: 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.<\/p>\nNo Discrimination<\/u><\/em>:<\/u>\u00a0We 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.<\/p>\nHow to Exercise Your Rights<\/u><\/em>: 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.<\/p>\nContact us<\/strong><\/p>\nFor any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.<\/p>\n Call us using the following toll-free number: (888) 413-2429.<\/p>\n Email us at the following email address: info@stgpartners.com.<\/p>\n We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request.\u00a0 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.\u00a0 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.<\/p>\n Please contact the Chief Compliance Officer of STG Partners at the email address above with any questions about this California Website Privacy Policy.<\/p>\n UK and EU Website Privacy Policy<\/h3>\nOur Commitment to Privacy<\/strong><\/p>\nYour privacy is important to STG Partners, LLC and its affiliates (together, “STG,” “Symphony,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.<\/p>\n This GDPR Website Privacy Policy describes how we gather and use personal data:<\/p>\n \n- from visitors of this website;<\/li>\n
- about representatives of our vendors, business partners or portfolio companies;<\/li>\n
- to conduct business with you;<\/li>\n
- from investors who use our online investor portal, in each case, that are from the EU or UK; and<\/li>\n
- through other data collection points where we refer to this Privacy Notice,<\/li>\n<\/ol>\n
and supersedes the Privacy Policy of STG linked to this website with respect to EU or UK users, as applicable.<\/p>\n This GDPR Website Privacy Policy does not apply to any processing of personal data by or on behalf of STG that is covered by a more specific privacy notice. Please read this GDPR Website Privacy Policy carefully.<\/p>\n For the purposes of applicable UK and EU data protection laws (“UK and EU Privacy Laws<\/strong>“), including Regulation (EU) 2016\/679 (the ‘EU GDPR<\/strong>‘), the General Data Protection Regulation as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act of 2018 and other legislation which implements any other current or future legal act of the EU or UK concerning the protection and processing of personal data and any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing, STG and its affiliated general partners and managing members will each be a data controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this GPDR Website Privacy Policy, please contact us at\u00a0info@stgpartners.com.<\/p>\nWe rely on various legal bases under UK and EU Privacy Laws in order to process your personal data (depending on the context, this may include your name, title, address, email, telephone number, marital status, date of birth, IP address, financial data, username, password and\/or government-issued identification, etc.), including for our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business, conduct business with you and provide you with the services and products we offer and perform essential or legitimate business operations. We do not collect any special categories of personal data 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.<\/p>\n 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. Failure to provide this information means that we cannot conduct business with or provide our services or products to you. In this case, we may have to cancel a business arrangement, product or service you have with us but we will notify you if this is the case at the time.<\/p>\n Further information about the legal bases under which we process your personal data is included in the section headed “Why we use your personal data.”<\/p>\n You do not need to take any action as a result of this GPDR Website Privacy Policy, but you do have certain rights as described below in the section headed “Your Rights.”<\/p>\n How We Obtain Your Personal Information<\/strong><\/p>\nInformation you provide to us<\/p>\n We collect your personal data when you decide to interact with us and we only collect the personal data necessary to carry out our business for the purposes set out in the section below headed “Why we use your personal data”. You can provide us with personal data via online form, email, post, telephone, when you visit our offices and this website and when you log into the investor online portal. We also collect information about you through automated technology when you access or use our website or investor online portal, such as cookies and similar technologies.<\/p>\n Information provided by third parties or publicly available sources<\/p>\n 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).<\/p>\n If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal data from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.<\/p>\n Why<\/strong>\u00a0We Use Your Personal Information<\/strong><\/p>\nWe will only use your personal data when the law allows us to. Most commonly, we will use your personal data: (i) where we need to perform the contract we are about to enter into or have entered into with you; (ii) where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests; and (iii) where we need to comply with a legal obligation. To the extent that you provide us with any personal data, 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 personal data for the following purposes:<\/p>\n \n\n\nPurpose<\/strong><\/td>\nLegal Basis<\/strong><\/td>\n<\/tr>\n\n| To provide you with the services or products you have requested, to communicate with you or conduct business with you.<\/td>\n | Contractual necessity, and\/or our legitimate interest in operating our business and providing investment services.<\/td>\n<\/tr>\n | \n| To keep a record of your relationship with us.<\/td>\n | Legitimate interest in operating our business and providing investment services.<\/td>\n<\/tr>\n | \n| To verify your identity.<\/td>\n | Legal requirement and\/or our legitimate interest in operating our business and providing investment services securely.<\/td>\n<\/tr>\n | \n| To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment which we are evaluating or are party to.<\/td>\n | Legitimate interest in operating our business and providing our investment services, contractual necessity, and\/or legal requirement.<\/td>\n<\/tr>\n | \n| Fraud, theft, money-laundering, cyber-attack, conflicts and abuse prevention.<\/td>\n | Legitimate interest in operating our business and providing investment services securely and legal requirement.<\/td>\n<\/tr>\n | \n| Litigation management and conducting internal audits and investigations.<\/td>\n | Legitimate interest in operating our business and legal requirement.<\/td>\n<\/tr>\n | \n| To administer and protect our business and this website.<\/td>\n | Legitimate interest in operating our business.<\/td>\n<\/tr>\n | \n| To make suggestions and recommendations to you about goods or services that may be of interest to you.<\/td>\n | Legitimate interest in operating our business.<\/td>\n<\/tr>\n | \n| To obtain advice from our professional advisors, including lawyers and accountants.<\/td>\n | Our legitimate interest in operating our business.<\/td>\n<\/tr>\n | \n| For statistical analysis and market research.<\/td>\n | Our legitimate interest in operating our business.<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n <\/p>\n No automated decision-making, including profiling, is used when processing your personal information.<\/p>\n Disclosure and Transfer of Personal Information<\/strong><\/p>\nUnfortunately, 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.<\/p>\n Your personal data 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 but not limited to administrators, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, industry advisors, recruitment firms, data hosting providers, placement agents, depositories, investment managers and other fund administrators. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 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 data is transferred to countries outside of the UK or EEA, such transfers will only be made in accordance with applicable UK and EU Privacy Laws. For further information about the safeguards\/derogations used, please contact us at\u00a0info@stgpartners.com.<\/p>\n 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, 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 data to the new owner of the relevant business and their advisors.<\/p>\n Security and Retention of Personal Information<\/strong><\/p>\nWe are committed to protecting the personal data you entrust to us. We adopt robust and appropriate data security technologies and policies, so the personal data we have about you is protected to the extent possible from unauthorized access and disclosure, improper use and accidental loss. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and required to keep your personal data secure.<\/p>\n We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.<\/p>\n We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this GPDR Website Privacy Policy unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact us at\u00a0info@stgpartners.com.<\/p>\n Capacity<\/strong><\/p>\nThis 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 data from an individual under the age of 18, we will delete that personal data.<\/p>\n Cookies<\/strong><\/p>\nInformation 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 us to provide the products and services you have requested or for the functioning of this website, we 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.<\/p>\n On this website we use Google Analytics to monitor website performance and to enhance user experience. The cookies used by Google Analytics are “analytics” or “performance” cookies, resulting in aggregated and anonymized information about how a user uses this website.<\/p>\n 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.<\/p>\n Your Rights<\/strong><\/p>\nYou have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact us at\u00a0info@stgpartners.com.<\/p>\n \n- 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.<\/li>\n
- Correction: You may notify us of changes to your personal data which we hold about you \u00a0if it is inaccurate or it needs to be updated.<\/li>\n
- Deletion: If you think that we should not 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.<\/li>\n
- 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 personal data for the purposes for which it was collected, but you still need your personal 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.<\/li>\n
- 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.<\/li>\n
- Portability: If you wish to transfer your personal data which we hold about you on the legal ground of contractual necessity to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.<\/li>\n
- 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.<\/li>\n<\/ol>\n
We may need to request specific personal data 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 personal data in relation to your request to speed up our response.<\/p>\n Notification of Changes<\/strong><\/p>\nWe reserve the right to amend this GPDR Website Privacy Policy from time to time by updating this GPDR Website Privacy Policy. If we decide to change our GPDR Website Privacy Policy, we will post those changes so our users are always aware of what personal data 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 GPDR Website Privacy Policy under which the personal data was collected.<\/p>\n Contact Us<\/strong><\/p>\nIf you have any questions or concerns about this GPDR Website Privacy Policy, please contact us at\u00a0info@stgpartners.com.<\/p>\n Complaints<\/strong><\/p>\nShould you wish to lodge a complaint with regards to how your personal data has been processed by us, under:<\/p>\n \n- the GDPR please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint; or<\/li>\n
- the UK GDPR and\/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https:\/\/ico.org.uk\/global\/contact-us.<\/li>\n<\/ol>\n
<\/p>\n updated November 05, 2023<\/em><\/p>\n\n","protected":false},"excerpt":{"rendered":"Our Commitment to Privacy Visitors that are residents of California should refer to our\u00a0California Website Privacy Policy. Visitors that are residents of the United Kingdom, the European Union or the European Economic Area should refer to our\u00a0EU Website Privacy Policy. 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![\"Privacy](\"https:\/\/stg.com\/wp-content\/uploads\/2022\/10\/Privacy-Policy-heading.svg\" "\\"Privacy")
\n\t