Our Commitment to Privacy
Your privacy is important to STG Partners, LLC and its affiliates (together, “STG,” “Symphony,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
The Information We Collect and How We Use It
We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, STG’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (IP) addresses. STG generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact Us” page.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
You may access any personally identifiable information we have about you by contacting us at email@example.com.
Notification of Changes
What information do we collect about you?
We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
|A. Identifiers||Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).||Yes|
|B. Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).||Yes|
|C. Protected classification characteristics under California or federal law||Date of birth, citizenship and birthplace.||No|
|D. Commercial information||Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).||No|
|E. Biometric information||Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.||No|
|F. Internet or other similar network activity||Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.||Yes|
|G. Geolocation data||Physical location or movements.||No|
|H. Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information||Current or past job history or performance evaluations.||Yes|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||Yes|
|K. Inferences drawn from other personal information||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
|L. Sensitive Personal Information (see further information on use of sensitive personal information below)||Social security, driver's license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer's mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer's health, sex life, or sexual orientation.||YES, as to the following types of information: account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only.|
We do not knowingly collect or solicit personal information from anyone under the age of 18.
We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business;
- To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Information from your communications with us in connection with this Website, including any update notices provided by you.
- Information captured on our Website, including registration and account information, information provided through online forms and any information captured via cookies.
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
How do we use your personal information?
We will use your personal information for one or more of the following business or commercial purposes:
- To perform services for you, including but not limited to the administrative processes (and related communication) in connection with an investment.
- To create, maintain, customize, and secure your account with us.
- To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
- To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
- To provide advertising and marketing services.
- To keep a record of your relationship with us.
- To conduct ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To keep investors informed about the business of the general partner or managing member of the applicable investment vehicle and its affiliates generally, including investor notices and reporting.
- To audit and verify the quality and effectiveness of our services and compliance.
- To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the "opt-out" or "unsubscribe" link provided in all our marketing emails.
We retain the categories of personal information set forth above in “What information do we collect about you?” section of this California Website Policy only as long as is reasonably necessary for those purposes set forth above in “How do we use your personal information?”, except as may be required under applicable law, court order or government regulations.
Who do we share your personal information with?
We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
|Personal Information Category||Category of Third-Party Recipients|
|A. Identifiers||Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))||Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.|
|C. Protected classification characteristics under California or federal law||N/A|
|D. Commercial information||N/A|
|E. Biometric information||N/A|
|F. Internet or other similar network activity||Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.|
|G. Geolocation data||N/A|
|H. Sensory data||N/A|
|I. Professional or employment-related information||Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.|
|K. Inferences drawn from other personal information||N/A|
|L. Sensitive Personal Information|
How do we keep your personal information secure?
We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom we disclose the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Call us using the following toll-free number: (888) 413-2429.
Email us at the following email address: firstname.lastname@example.org.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Our Commitment to Privacy
Your privacy is important to STG Partners, LLC and its affiliates (together, “STG,” “Symphony,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
- from visitors of this website;
- about representatives of our vendors, business partners or portfolio companies;
- to conduct business with you;
- from investors who use our online investor portal, in each case, that are from the EU or UK; and
- through other data collection points where we refer to this Privacy Notice,
We rely on various legal bases under UK and EU Privacy Laws in order to process your personal data (depending on the context, this may include your name, title, address, email, telephone number, marital status, date of birth, IP address, financial data, username, password and/or government-issued identification, etc.), including for our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business, conduct business with you and provide you with the services and products we offer and perform essential or legitimate business operations. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot conduct business with or provide our services or products to you. In this case, we may have to cancel a business arrangement, product or service you have with us but we will notify you if this is the case at the time.
Further information about the legal bases under which we process your personal data is included in the section headed “Why we use your personal data.”
How We Obtain Your Personal Information
Information you provide to us
We collect your personal data when you decide to interact with us and we only collect the personal data necessary to carry out our business for the purposes set out in the section below headed "Why we use your personal data". You can provide us with personal data via online form, email, post, telephone, when you visit our offices and this website and when you log into the investor online portal. We also collect information about you through automated technology when you access or use our website or investor online portal, such as cookies and similar technologies.
Information provided by third parties or publicly available sources
We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).
If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal data from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
Why We Use Your Personal Information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data: (i) where we need to perform the contract we are about to enter into or have entered into with you; (ii) where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests; and (iii) where we need to comply with a legal obligation. To the extent that you provide us with any personal data, through or in connection with this website (i.e., via online form, telephone, email or post) or the investor online portal, we may use such personal data for the following purposes:
|To provide you with the services or products you have requested, to communicate with you or conduct business with you.||Contractual necessity, and/or our legitimate interest in operating our business and providing investment services.|
|To keep a record of your relationship with us.||Legitimate interest in operating our business and providing investment services.|
|To verify your identity.||Legal requirement and/or our legitimate interest in operating our business and providing investment services securely.|
|To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment which we are evaluating or are party to.||Legitimate interest in operating our business and providing our investment services, contractual necessity, and/or legal requirement.|
|Fraud, theft, money-laundering, cyber-attack, conflicts and abuse prevention.||Legitimate interest in operating our business and providing investment services securely and legal requirement.|
|Litigation management and conducting internal audits and investigations.||Legitimate interest in operating our business and legal requirement.|
|To administer and protect our business and this website.||Legitimate interest in operating our business.|
|To make suggestions and recommendations to you about goods or services that may be of interest to you.||Legitimate interest in operating our business.|
|To obtain advice from our professional advisors, including lawyers and accountants.||Our legitimate interest in operating our business.|
|For statistical analysis and market research.||Our legitimate interest in operating our business.|
No automated decision-making, including profiling, is used when processing your personal information.
Disclosure and Transfer of Personal Information
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this website; any transmission of information or data by you to or through this website is at your sole risk.
Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including but not limited to administrators, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, industry advisors, recruitment firms, data hosting providers, placement agents, depositories, investment managers and other fund administrators. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We seek assurances that our standards for data security are met by anyone who enters into an agreement providing a service to, or for us, involving personal data. To the extent your personal data is transferred to countries outside of the UK or EEA, such transfers will only be made in accordance with applicable UK and EU Privacy Laws. For further information about the safeguards/derogations used, please contact us at email@example.com.
We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors.
Security and Retention of Personal Information
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate data security technologies and policies, so the personal data we have about you is protected to the extent possible from unauthorized access and disclosure, improper use and accidental loss. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and required to keep your personal data secure.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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 the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that personal data.
On this website we use Google Analytics to monitor website performance and to enhance user experience. The cookies used by Google Analytics are “analytics” or “performance” cookies, resulting in aggregated and anonymized information about how a user uses this website.
You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what personal data we store and process about you. To exercise these rights and controls, please contact us at firstname.lastname@example.org.
- Access: You have the right to ask for a copy of the personal data that we hold about you free of charge; however, we may charge a “reasonable fee” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to your personal data which we hold about you if it is inaccurate or it needs to be updated.
- Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your personal data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer your personal data which we hold about you on the legal ground of contractual necessity to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific personal data from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further personal data in relation to your request to speed up our response.
Notification of Changes
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, under:
- the GDPR please contact your local supervisory authority in particular in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint; or
- the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us.
updated November 05, 2023