PRIVACY POLICY

Last updated:  September 1, 2020

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”)) respects 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 information about you, including information derived from your visit to our website and information you may provide in connection with your employer’s business with us. 

We may collect various types of information about you or your employer, including information you voluntarily provide to us when you use this website, send an email to [email protected], or call our office telephone numbers listed on this website. We rely on various legal bases to maintain that information, including your consent, our legitimate business interests, website utility and efficiency, and legal requirements. We use the information we collect to enhance our business and our relationship with potential partner 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.  

This Privacy Policy does not address personal information we collect from our actual or prospective employees or individual investors in our funds. If you fit in one these categories, we will provide you a separate privacy notice applicable to those relationships. 

Data Automatically Collected

In general, when you visit our website we may automatically collect certain usage information, such as the number and frequency of your visits, the websites you access immediately after your visit to our website, the Internet browser you are using, and your IP address.

Personal Information We Collect

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. 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.

We may engage service providers to perform work on our behalf, such as sending postal mail and e-mail. These persons may have access to the personal information you submit to us, but only to perform their duties. We direct these persons not to use your personal information for any other purpose. 

You do not need to take any action based on this Privacy Policy, but you do have certain rights as described below under Your Rights.

Disclosure and Transfer of Personal Information

We will not provide or transfer any of your personal information to any other persons, except (a) to our service providers, (b) with your permission, or (c) if we are required to make disclosures to governmental or private parties in connection with a regulatory examination or inquiry, lawsuit, subpoena, discovery request, investigation, arbitration or other proceeding. We can (and you authorize us to) disclose any such information in those circumstances. We do not sell your personal information as that term is defined under the California Consumer Protection Act.  

How and Why We Use Your Personal Information

To the extent you provide us with any personal information, including through or in connection with our website (i.e., via telephone, email or postal mail), we may use such information for the following purposes and to comply with certain legal bases recognized by the European Union’s General Data Protection Regulation (“GDPR”), as indicated in the following table:

Purpose

Legal Basis

Investment Due Diligence: To explore potential investment transactions.

Necessary to perform contracts; and Legitimate interest

Build Relationships:  If you are a business owner or investor, we may contact you to provide information about opportunities to partner with us.

Legitimate interest

Improving Our Website: We use information you provide in visiting our website to understand your interests and consider how we can improve our website.

Legitimate interest

Legal and Regulatory Compliance: To verify the identity of you or your employer; manage threatened or actual litigation matters; or conduct internal audits or reviews.

Legitimate interest; and 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. We employ technologies and procedures to protect information we have about you from unauthorized access and improper use, to the extent reasonably practicable. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need for the information and whom we instruct to protect it.

We do not intend to keep your personal information for 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

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 identify and understand the needs of potential partner companies. We use a web analytics service to help us understand how users use the 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.  

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. 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”), California, and various other jurisdictions provide their residents with certain legal rights regarding their personal information. These laws include the GDPR and California’s Consumer Privacy Act (the “CCPA”). We will comply with our legal obligations under these regulations for residents of those jurisdiction.  Generally, the GDPR and CCPA, with certain time limitations depending on the jurisdiction, provide that you have the right to know what personal information we hold or have collected about you within a particular time frame. Among those rights are the following:

  • Access: You have the right to ask for a copy of the personal information we hold about you, the categories of personal information we collect about you, the sources from which we collect personal information, the business or commercial purpose for which we collect the personal information, and the categories of third parties with which we have shared your personal information.
  • Correction: You may notify us of changes to your personal information.
  • Deletion: If you think we should no longer be holding or processing your personal information, you may request that we delete it. We will honor your request unless our legal obligations prohibit us from doing so, or if we otherwise have a right to retain the personal information under applicable law.
  • Object: You have the right to object to processing, including: (a) for direct marketing; (b) for research or statistical purposes; or (c) where processing is based on legitimate interests.
  • Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to the processing of your personal information for a particular purpose, but wish to withdraw that consent, you can do so by notice to us.
  • Non-Discrimination: We will not discriminate against you for exercising the rights described in this Privacy Policy.

 

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 security measure helps ensure personal data is not disclosed to any person who has no right to receive it.

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.

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 to [email protected].