Privacy Policy

Last updated: April 1, 2025

Seidler Equity Partners (the informal name for the private investment group consisting of Seidler Kutsenda Management Company LLC and its affiliated entities (collectively, “Seidler Equity Partners,” “we” or “us”)) respect your privacy rights.  Our address is 4640 Admiralty Way, Suite 1200, Marina del Rey, CA 90292, USA.  We are the controller of personal information collected from you.

This Privacy Policy describes how and when we gather and use personal information about you, including personal information derived from your visit to our Website at www.sepfunds.com (the “Website”), applying for a job through the Website, and information you may provide in connection with your employer’s business with us.  It does not apply to personal information collected from or about employees or potential or actual investors in any of our funds or any of our portfolio companies.

We collect information in two ways: (a) automatically when you visit our Website, and (b) when you voluntarily provide that information, such as in connection with our interactions with your business, when you use this Website, send an email to info@sepfunds.com, or call our office telephone numbers listed on this Website.

Data Automatically Collected

In general, when you visit our Website, we may automatically collect certain usage information, such as the number, length and frequency of your visits, the pages you view, the Websites you access immediately after your visit to our Website, the Internet browser you are using, and your device ID and IP address.  See the section entitled Cookies for more information on how we collect this information.

Personal Information We Collect From Website Users

When you use our Website, and in our business dealings with you or your employer, we may collect your “personal information.”  Personal information is information that can, either alone or in combination with other information, directly or indirectly identify you, or that is protected as personal information or personal data or similar term under applicable law.  Examples of personal information we collect include your name, company, title, telephone number, mailing address, email address, and other information regarding you or your employer where it is relevant to our interactions with actual or potential partner companies.  If you voluntarily submit information to us, for example, by making an inquiry by email or telephone call, we may record and use that information as set forth in this Privacy Policy.

Purposes for Processing Personal Information

We use the personal and other information we collect from you for the following purposes:

  • To provide, develop and improve the Website;
  • To monitor, facilitate and process investment transactions;
  • To respond to your inquiries and provide technical support and customer service;
  • To conduct business development and send you email and other forms of marketing communications;
  • To (a) ensure our Website is working as intended, (b) operate our business, better understand how users access and use our Website, both on an aggregated and individualized basis, (c) develop, maintain, protect, and improve our Website, and (d) perform research and analytics, including to analyze and report on usage and performance of our Website;
  • To detect, investigate, and prevent activities on our Website that may violate our security, could be fraudulent, violate copyright, or other rules or that may be otherwise illegal, to comply with legal requirements and legal process and court orders, to defend or exercise legal claims, to respond to law enforcement or governmental investigations or requests, and to protect our rights and the rights and safety of our users and others; and
  • For other purposes consistent with any consent that you have provided.

Disclosure and Transfer of Personal Information

We will not provide or transfer any of your personal information to any other persons, except as follows:

Consent.  Where you have provided consent, we share your information, including personal information, as described at the time of consent.

Affiliates.  We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing the Website to you and in connection with any investments; however, if we do so, their use and disclosure of your personal information will be maintained by such affiliates and subsidiaries in accordance with this Policy.

Service Providers.  We may disclose the information we collect from you to third-party vendors, service providers, contractors or agents who perform functions on our behalf, such as providing storage services.

Business Transfers.  We may transfer your personal information in connection with a corporate merger, acquisition, sale of assets, bankruptcy, or other change in corporate status in which information is transferred to one or more third parties as one of our business assets, including to prospective buyers or investors of our company or its assets.

In Response to Legal Process or Governmental Requests.  We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena or civil discovery requests or in response to requests from law enforcement or regulatory or governmental entities.

To Protect Us and Others.  We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our agreements and policies, or as evidence in litigation in which we are involved.

We do not sell or provide your personal information to third parties for their own direct marketing purposes.

Legal Bases for Processing Personal Information

Certain jurisdictions require us to disclose the legal bases for processing your personal information.  To the extent we collect personal information that is subject to the European Union’s General Data Protection Regulation (“GDPR”) or the United Kingdom’s version of the GDPR (“UK GDPR”) we rely upon the following legal bases:

  • We rely upon our legitimate interest to process your personal information to respond to your inquiries, to send you marketing and other information, and manage and monitor usage of our Website.
  • We rely upon necessity to enter into and perform a contract to process your information in connection with employment inquiries, applications, and investments.
  • We rely upon consent in certain circumstances. You can withdraw your consent at any time by emailing us at privacy@sepfunds.com.
  • We also process your personal information as necessary to comply with legal obligations.

No automated decision-making, including profiling, is used when processing (as defined in the GDPR) your personal information.

Security and Retention of Personal Information

We endeavor to protect the personal information you provide to us by using reasonable measures designed to protect such information from unauthorized access or use.  Please be aware that despite our efforts, no data security measures can guarantee 100% security.

We do not intend to keep your personal information any longer than is reasonably necessary for the purposes described in this Privacy Policy unless a law or regulation requires a longer retention period.  We endeavor not to keep more information than we need for those purposes.  It is possible that even when we delete or destroy personal information about you, it may still reside on electronic storage or backup tapes.

Legal Age/Children

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 that age, nor do we knowingly collect personal information from anyone under that age without parental consent.  If we learn we have collected or received personal information from an individual under the age of 18, we will delete it.

Cookies

Information 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.  We use this information to help us monitor and improve our Website and identify and understand the needs of potential partner companies.

We may also use “tracking pixels” or “web beacons,” which are small graphics files embedded in our Website that contain a unique identifier that allows us to recognize when someone has visited our Website.

By using the Website, you consent to the use of cookies, tracking pixels or web beacons to collect information about your interactions with our Website and your IP address and device identifier.  This information may be shared with the third-party providers of such cookies, tracking pixels or web beacons.

There are two types of cookies: session and persistent cookies.

  • Session Cookies. Session cookies exist only during an online session.  They disappear from your computer when you close your browser or turn off your computer.  We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Website.  This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Website.
  • Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer.  We use persistent cookies to track aggregate and statistical information about user activity.

We use a web analytics service (Google Analytics) to help us understand how visitors use our Website.  If you prefer not to receive cookies through our Website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence.  You can also refuse all cookies by turning them off in your browser.  To opt-out of Google Analytics and find out more about their privacy practices, see https://tools.google.com/dlpage/gaoptout.

We use Bombora to collect information from visitors to our Website, what pages they visit, and how long they are on our pages.  We use this information to identify and understand the users that visit our Website and to manage and improve our Website.  For more information on the data Bombora collects, please see their privacy policy at https://bombora.com/privacy-policy/.

You may want to visit www.allaboutcookies.org for more information about types of cookies, how they are used, and how you can manage your cookie preferences.

Do Not Track

Currently, our systems do not recognize browser “do-not-track” requests.  You may, however, disable certain forms of tracking as described earlier in this section (e.g., by disabling cookies in your browser).

Your Rights

The European Union (the “EU”), the United Kingdom (“UK”), California, and various other jurisdictions provide their residents with certain legal rights regarding their personal information.  Your rights under California are described in the California Privacy Notice section.  If you are a resident of the EU or the UK, you have the following rights:

  • Right to access and rectification: You can request personal information we hold and the correction of any errors of your personal information.
  • Right to erasure/deletion: The right, in certain circumstances, to ask for your personal information to be deleted. In specific cases, we may not be able to delete some types of personal information, in particular, where we have a legal obligation to keep that personal information (e.g., for regulatory reporting purposes), or where you want us to continue to provide you with a service and the processing of the personal information is necessary for the provision of that service.
  • Right to restriction of processing: The right, in certain circumstances, to restrict further processing of your personal information.
  • Right to portability: The right in some cases to receive your personal information in a digital format or to have it transmitted directly to another controller (where technically feasible).
  • Right to object: The right to object (on grounds relating to your particular situation) to the processing of your personal information on the basis of our legitimate interests, including for direct marketing purposes.
  • Right to withdraw consent: You can withdraw your consent at any time in respect of any processing of personal information, which is based upon a consent.

If you believe our processing of your personal information violates data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.  You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged violation.  Residents of the UK can file a complaint with the personal information Commissioner’s Office at https://ico.org.uk/make-a-complaint/.

Australia

If you are a resident of Australia, we are committed to treating the personal information we collect in accordance with relevant laws, including the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act).  For more information about privacy and the protection of personal information, visit the Office of the Australian Information Commissioner Website www.oaic.gov.au.

We will respond to requests and complaints as required by the Privacy Act.  You can make a request or submit a complaint at privacy@sepfunds.com.  If you are not satisfied with our response or the manner in which we have dealt with your complaint, you can refer your complaint to the Office of the Australian Information Commissioner.

California Privacy Notice

Notice of Collection and Information Collected in the Past 12 Months: We collect, and during the past 12 months have collected, the following categories of personal information for the following business and commercial purposes.  We do not sell or share this information as those terms are defined under the CCPA; we do not sell or share the personal information of persons under the age of 16.

Category Business and Commercial Purpose
Identifiers, such as name, email, address, social security number and phone number. To provide the Website, respond to inquiries, provide information on investments, process employment applications and investments, for marketing and business development purposes, and as specified in the section entitled Purposes for Processing Personal Information.
Any personal information described in subdivision (e) of Section 1798.80 – see Identifiers. See identifiers.
Protected Classifications – gender and nationality. To process employment applications and comply with legal reporting obligations.
Internet or other electronic network activity information as described in the section entitled Data Automatically Collected. To track usage and improve the performance and features of the Website and for marketing and business development purposes.  See sections entitled Data Automatically Collected and Cookies.
Professional and Employment Information. For business development and marketing purposes and to process employment applications as specified in the section entitled Purposes for Processing Personal Information.

 

Please note that all of the categories of personal information we collect about you (as detailed above) come from the following categories of sources:

  • You or your employer or company, including through your use of our Website or in responding to our requests;
  • Automatically collected from you through the use of cookies;
  • Our affiliate companies; and
  • Third parties, such as the funds in which you invest.

We have disclosed your personal information to the following third parties for the following business purposes: partner companies and funds in connection with your investment in the same.

You have the following rights under the CCPA:

  1. The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you;
  2. The right to delete personal information that we have collected from you, subject to certain exceptions;
  3. The right to correct inaccurate personal information that we maintain about you; and
  4. The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

Opt-Out of Sale or Sharing of Personal Information: We do not offer the right to opt-out of the “selling” or “sharing” your personal information since we do not sell or share your personal information as such terms are defined under the CCPA.

Right to Limit Use and Disclosure of Sensitive Personal Information: We do not offer the right to limit the use or disclosure of sensitive personal information because we do not use such information to infer characteristics or for purposes that would require offering this right.

Exercising Your Rights

You can exercise your rights to your personal information as described herein by submitting your request to privacy@sepfunds.com.

In order to process a request, we will need to verify your identity.  If your request concerns “categories” of personal information collected, we may request from you two data points of personal information to verify your identity.  If your request concerns specific personal information, we may request from you at least three data points of personal information as well as a signed declaration with penalty of perjury to verify your identity.

Your authorized agent may also make requests under the CCPA on your behalf by following the process described above.  In such a case, we may require you to do either of the following:

(1) Verify your own identity directly with us; or

(2) Directly confirm with us that you have provided the authorized agent permission to submit the request.

We will not impose these requirements where you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130.

Requests under the CCPA will be processed as follows: we will send you a receipt, acknowledging your request, within 10 business days, which will be processed according to the CCPA regulations.  If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to privacy@sepfunds.com as an error may have occurred.  We will process and respond to your request within 45 days after it is received (in some cases, as is allowed under the CCPA, this process may be extended by an additional 45 calendar days).

Requests under the GDPR or UK GDPR will be processed within 30 days (subject to our right to extend this period as permitted under the law) of receipt of your request, subject to verification of your identity.

Transfer of Personal Information

We are based in the United States and will collect and store your personal information in the United States, which may have less protections than your jurisdiction of residence.  You consent to the transfer of your personal information to the United States.

In some cases, the third parties we may disclose your personal information to may be based outside of your jurisdiction of residence.  If your personal information is transferred to a jurisdiction that does not have data protection laws as comprehensive as your country of residence, we will take commercially reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the laws of your jurisdiction of residence.

Future Changes

We may change this Privacy Policy from time to time by updating and posting it to this Website.  If we decide to collect personal information, or use any collected information, in a manner different from that stated when it was collected, we will notify the affected users.  We will use information only in accordance with the Privacy Policy under which we collected the information.

Contact

Please address any questions, comments, and requests regarding this Privacy Policy by email to privacy@sepfunds.com or by mail to:

Seidler Equity Partners

4640 Admiralty Way, Suite 1200

Marina del Rey, CA 90292, USA