This privacy notice describes how Parthenon collects, uses and shares the personal information we gather about you that you provide to us via our website (www.parthenoncapital.com) (the “Site”).
If you are a natural person invested in a fund advised by Parthenon or you are an employee of an entity 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.
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 while viewing the Site.
We hold onto information you provide to us on the Site 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 other business opportunities. The information you provide on the Site in order to contact a member of our Team may be deemed sensitive under applicable data protection laws. We will use such information only for lawful purposes and will not sue sensitive personal information provided to infer characteristics about you other than as required to comply with law or legal process.
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 do not sell or exchange for value any personal information that you provide to us on the Site, nor do we share such information for targeted advertisements such as cross-context behavioral advertising.
We reserve the right to disclose nonpublic personal information that you provide to us on the Site to any person or entity as permitted by law and as we determined to be necessary or desirable in connection with our everyday business purposes, including Parthenon’s investment activities and the administration and oversight of the pooled investment vehicles, special purpose vehicles and other entities we advise or manage in connection with our investment activities. The following are examples of third parties with whom we may share nonpublic personal information about you: (i) our affiliates, including current or former portfolio companies, (ii) our service providers such as our accountants, auditors, tax return preparers, attorneys, banks, lenders (including private entities), broker-dealers, other financial institutions, registered agents, compliance consultants, and fund administrators, (iii) other third parties in connection with our investment activities; (iv) to comply with applicable law, any court order or subpoena, or an information request from a regulatory authority, including in connection with compliance with laws relating to combatting money laundering, terrorism and other illicit activities, and (v) as necessary for us to establish, exercise or defend against a legal claim. Our service providers who receive non-public personal information may also disclose such information for similar purposes.
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.
To protect the nonpublic personal information of individuals retained in our data systems, we permit access to that information only by authorized employees and service providers who need access to that information to provide services to us and the entities advised or managed by us. We maintain physical, electronic and procedural safeguards designed to protect that information. Despite the security measures that we have put in place, no such measures can guarantee security or protect against unauthorized activity.
Nonpublic personal information subject to this notice will only be retained for so long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, accounting, reporting, and recordkeeping requirements. When deciding how long to retain your nonpublic personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your nonpublic information, the purpose for which we process your personal information and whether we can achieve those purposes through other means.
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 or regulations.
The 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.
The 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 the Site, and/or providing us with your information, you consent to the transfer of your information to the United States.
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.
To make the 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. The 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 a third-party platform that facilitates delivery of financial reports, tax filing and return information, and other communications from our funds (the “LP Portal”). The LP Portal 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 the LP Portal’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.
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 and at our sole discretion. If you are not comfortable with this Policy or any future updates, you should not use (or continue to use) the Site. Please review updates to this Notice before providing any nonpublic information to us via the Site.
If you have questions about our privacy policies or personal information handling practices, please contact us using the information on our Contacts page or at privacy@parthenoncapital.com.