Effective January 9, 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.
Our Site does not directly collect any personal information at this time. You may provide us directly 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 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
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.
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.
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.
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.
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.
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.
If you have questions about our privacy policies, please contact us using the information on our Contacts page or at [email protected]