Parthenon Website Privacy policy
Effective May 5, 2020
Parthenon considers privacy to be fundamental to our relationship with various third parties. We are committed to maintaining the confidentiality, integrity and security of non-public information that we collect through various means, including our website (www.parthenoncapital.com) (the “Site”). Accordingly, we have developed internal policies to protect confidentiality while allowing us to serve the needs of our clients and other parties.
If you are invested in a fund advised by Parthenon, please refer to the investor privacy notice, available on our investor portal, for information about our collection, use and sharing practices with respect to investor information.
Information We Collect
Except for information necessary to use the “Login” feature, our Site does not directly collect any personal information at this time. You may provide us with information if you choose to contact us by email or otherwise contact us to solicit our services or provide services to us, or if simply requesting information about us. Your personal information may include your name, email address, name of your company, and any other information that you choose to provide to us.
You are not required to provide any information to us. However, we may be unable to provide certain services to you or agree to accept services from you if you do not provide us with information that we determine is necessary to facilitate those services or to comply with applicable law. For example, we collect information from prospective investors to assess the investor’s overall investment acumen and suitability to invest in the pooled investment vehicles and other investment opportunities offered by Parthenon. We also collect identifying information, such as copies of driver’s licenses and/or passports and similar identification documents, bank account information, and social security numbers and other tax-related information, for purposes of complying with our anti-money laundering compliance policies and procedures. We are unable to provide services to prospective investors who do not provide this information. Similarly, we collect information on employment applications from candidates seeking employment with Parthenon or its portfolio companies. Failure to provide the requested information may prevent us from evaluating an applicant’s qualifications for a particular position.
We may also collect information from third parties, such as information available from public records, information published by regulatory authorities, such as information we procure in connection with our anti-money laundering compliance policies and procedures, or through social media searches. We may also obtain information from vendors or other service providers we engage to conduct background checks, in connection with due diligence on prospective portfolio companies, or reference calls.
We hold onto information we collect for as long as necessary to fulfill the purposes for which we collected such information or as we may be permitted or required to retain such information pursuant to applicable laws. In particular, if you choose to contact a member of our Team through our Site, please note that your contact and any other information you choose to provide to us on the Site will be retained so that we may contact you in the future, such as to respond to your inquiry or to offer you investment services or other business opportunities.
How We Use the Information We Collect
We may use the information we collect from you for the purpose you provided it to us. For example, we may use your contact information to respond to an inquiry to us and any related activity that may result from your inquiry. We may also use your information to provide our investment services, including evaluating investment opportunities that may be suitable for you. Personal information is also used to communicate with prospective investors, including notices of new offerings, co-investment opportunities and updates on our investment activities.
How we Share the Information We Collect
We do not sell or exchange for value any personal information. In the normal course of serving the pooled investment vehicles and portfolio companies we manage, personal information we collect may be shared with companies that perform various services such as our accountants, auditors, attorneys, broker-dealers and fund administrator. Specifically, we may disclose to these service providers non-public personal information including:
Any party that receives this information will use it only for the services required and as allowed by applicable law or regulation and is not permitted to share or use this information for any other purpose.
In addition, we and our service providers may disclose personal information (i) if we are required or permitted to do so (i) to comply with our compliance policies and procedures, (ii) to comply with applicable law, any court order or subpoena, or an information request from a regulatory authority, (iii) when we determine disclosure may be necessary to prevent physical harm or financial loss, including sharing information with vendors for fraud protection or to prevent against cybersecurity threats, (iv) in connection with investigations of fraudulent or other illegal activity, and (v) if we merge or partner with other companies or sell or transfer all or any portion of our business or assets, such as information we provide in connection with diligence requests in anticipation of such transactions.
California Consumer Privacy Statement
This statement does not apply to (i) Parthenon personnel or applicants seeking employment opportunities with Parthenon, (ii) personnel working on behalf of our business partners, or (iii) any information collected, processed, sold or disclosed pursuant to the federal Gramm-Leach-Bliley Act (and the regulations thereunder).
Individuals entitled to exercise their rights under the California Consumer Privacy Act have the right to request that we disclose the following:
Please contact us using the information on our Contacts page to request any of the foregoing information free of charge. You have the right not to receive discriminatory treatment if you exercise any of these rights. In addition, you have the right to request that we delete any personal information we have collected pertaining to you, except to the extent retention of such information is necessary for us or our service providers to provide ongoing services to the pooled investment vehicles we manage and to comply with applicable law.
Other Third Party Web Sites
This Site contains links to other web sites, including Intralinks. We are not responsible for the privacy practices of such other sites. Please review the privacy policies and statements of the sites you visit that collect your information.
Data Transfers
This Site is controlled and operated from the United States and is not intended to be subject to the laws or jurisdiction of any country or territory other than that of the United States. By using this Site, investing in our funds and/or providing us with your information, you consent to the transfer of your information to the United States.
Security
We have implemented appropriate technical and physical security measures to protect against the loss, misuse or alteration of your information. However, we cannot guaranty that these measures will prevent unauthorized access or transmission of your information. Please contact us if you have any reason to believe that the information we have collected pertaining to you is not secure.
Our Cookies Policy
To make this Site work properly, our web server sends a small text file to your browser that is stored on your computer or mobile device when you visit our Site. This Site uses primarily performance cookies. These cookies enable us to collect information about how visitors use the Site, for instance which pages visitors go to most often and if they get error messages from the web pages. These cookies help our web server to maintain the Site in proper working order. You can manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. However, you may experience some limited functionality while visiting our Site if you block all cookies. You can find more information about cookies generally here: www.allaboutcookies.org.
The “Login” section of our Site consists of a link to WebLP, which is a third party platform that facilitates delivery of financial reports, tax filing and return information, and other communications from our funds. WebLP uses cookies to identify your device as you use their site to login to access the funds’ reports and other information. Generally, these cookies last only the duration of each session. Please refer to WebLP’s cookies policy for additional disclosures on the cookies used when you login. Our Site also includes a link to our page on LinkedIn. We encourage you to review LinkedIn’s cookie policy before viewing our LinkedIn page.
Updates to this Policy
This Notice is not intended to be incorporated in any offering materials but is merely a statement of Parthenon’s current Web Site Privacy Policy and may be amended from time to time at any time. If you are not comfortable with this Policy or any future updates, you should not use (or continue to use) the Site.
Questions about this Policy
If you have questions about our privacy policies, please contact us using the information on our Contacts page or at privacy@parthenoncapital.com