GDPR Privacy Notice

Last Modified: June 10, 2023

Your privacy is important to Springcoast Capital Partners, L.P. and our affiliates (together, “Springcoast”, “our”, “us”, or “we”). This GDPR website privacy notice (this “Website Privacy Notice”) will inform you as to how we look after your personal data, how and why we collect it, tell you about your privacy rights, and how the law protects you. Please read this Website Privacy Notice carefully.

This Website Privacy Notice applies only if our collection, or your provision, or personal data under this notice is subject to the EU and UK Privacy Laws (as defined below).

This Website Privacy Notice provides you with important information about the personal data that we collect, and that you directly provide to us, when you interact with us via our websites (including those accessible at www.springcoast.com), online portals or data rooms (together, the “Websites”), including via our contact details as set out at our Websites. Note, this Website Privacy Notice does not apply to any processing of personal data by or on behalf of Springcoast that is covered by a more specific privacy notice.

You do not need to take any action as a result of this Website Privacy Notice, but you do have certain rights as described below in the section headed “Your rights”.

For the purposes of applicable UK and EU data protection laws, including the General Data Protection Regulation (EU) 2016/679 (the “EU GDPR”), the UK equivalent of the EU GDPR (the “UK GDPR”) and the Data Protection Act 2018 (collectively, “the EU and UK Privacy Laws”), Springcoast will be a controller of any personal data collected by us when you interact with us in the ways described above (e.g., when you visit our website, etc.). If you have any questions regarding our use of your personal data, or this Website Privacy Notice, please contact privacy@springcoast.com.

THE PERSONAL DATA WE PROCESS AND HOW WE COLLECT IT

We collect personal data about you:

that you specifically provide to us via any of our Websites;
when you opt to receive communications from Springcoast;
through automated technology when you access and use any of our Websites, such as cookies and similar technology – please see the “Cookies” section below for information about how we use such automated technologies; and
that third parties provide to us.

We collect certain types of personal data about you depending on the nature of your interaction with us. Such data may include identity data, contact data, technical data, profile data (e.g. username and password).

We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated, or incompatible purposes without notice.

We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data (including basic contact and identifying information and IP addresses, and, where appropriate, more sensitive types of personal data such as passport information and financial information, 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 perform essential or legitimate business operations. We do not deliberately collect or solicit 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 deliberately collect or solicit any personal data 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 may mean that we cannot conduct business with you. If you refuse to provide other types of personal data, you may not receive an optimised experience visiting our website and/or we may be unable to properly communicate you in response to any enquiry.

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”.

We collect your personal data in the following ways, 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”:

Information you provide to us

We collect your personal data when you decide to interact with us via our Websites (e.g., via the contact details provided on the Websites) including any personal data that you disclose as part of those communications.

We may also collect personal data about you such as your IP address through automated technology when you access and use our Websites, such as cookies and similar technology – please see the “Cookies” section below for information about how we use such technologies.

Information provided by third parties or publicly available sources

We may receive personal data about you from third party sources including any third parties whose cookies and similar technology are deployed when you access our Websites and third parties who host or administer our Websites.

WHY WE USE YOUR PERSONAL DATA

To the extent that you provide us with any personal data, or we otherwise collect your personal data (i.e., through or in connection with our Websites) we may use your personal data for the following purposes (which shall be considered “business purposes” for purposes of the CCPA (defined below)):

Purpose	Legal Basis
To conduct business with you or to provide you with the services you have requested	Contractual necessity; and/or our legitimate interest in operating our Websites and business
To support and communicate with you	Our legitimate interest in operating our Websites and business
To keep a record of your relationship with us	Our legitimate interest in operating our Websites and business; and/or legal requirement
To administer, support, develop, and protect our business and our Websites	Our legitimate interest in operating our business
For statistical analysis and market research	Our legitimate interest in operating our business
To comply with applicable laws, rules, and regulations, including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations	Our legitimate interest in legally operating our business
For any other purpose that has been notified, or has been agreed, in writing	Consent

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.

No solely automated decision making, including profiling, is used when processing your personal data.

MARKETING COMMUNICATIONS

We will only send you marketing newsletters, updates, alerts and similar marketing or promotional communications where you have requested information from us relating to our business or services which you might be interested in or where we are otherwise permitted to do so. You may request that we stop sending you marketing communications by emailing privacy@springcoast.com at any time.

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 our Websites; any transmission of information or data by you to or through our Websites 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. We use a number of service providers that provide a wide range of services including legal and financial professional advisors, IT and data security providers, data hosting providers and website managers and other IT service providers, meetings and conference vendors, auditors, marketing agencies, recruiters and HR firms, and data software providers. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. To the extent your personal data is transferred to countries outside of the UK or the European Economic Area, such transfers will only be made in accordance with the EU and UK Privacy Laws. For further information about the safeguards used, please contact privacy@springcoast.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 DATA

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate data security technologies, measures and policies, so the information 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 and who need to know that personal data. 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. We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Website Privacy Notice, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact privacy@springcoast.com.

CAPACITY

Our Websites are only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to our Websites who are under the age of 18 or knowingly collect personal data 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 information.

COOKIES

Information regarding how you access the Websites (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 device) or other technologies or tools. This information is used to improve the Websites’ performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of the relevant Website, we will ask you to consent to their use. 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 web sites you visit instructing them not to place cookies on the device running that browser. Our website accessible at www.springcoast.com is able to respond to such instructions. For more information about how to do this, look at your browser ‘help’ section or visit www.allaboutcookies.org and www.youronlinechoices.eu. If you opt-out of certain cookies (whether by activating Do Not Track features or otherwise not consenting to the placement of non-essential cookies, for example via our cookies pop-up) that may mean that you will not be able to access certain parts of features of our Websites.

Subject to your consent, our website accessible at www.springcoast.com will place the following non-essential cookies:

Cookie	Name	Type / Purpose	More Information
Google Analytics	ga,_gat,_gid	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, approximate geolocation, browser and device and the pages they visited.	Google Privacy Policy You can also opt out of using Google Analytics cookies here: http://tools.google.com/dlpage/gaoptout

Cookie

Name

Type / Purpose

More Information

Google Analytics

ga,_gat,_gid

These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, approximate geolocation, browser and device and the pages they visited.

Google Privacy Policy

You can also opt out of using Google Analytics cookies here: http://tools.google.com/dlpage/gaoptout

YOUR RIGHTS

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 privacy@springcoast.com.

Access: You have the right to ask for a copy of the personal data that we hold and process 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 have a right to request that we correct your personal data if the information we hold and process about you is inaccurate or it needs to be updated.
Deletion: If you think that we shouldn’t be holding or processing your personal data any more, 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 the personal data that we hold and process about you on the legal ground of contractual necessity to another organisation (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 not specified in this Website Privacy Notice, 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 information 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 information in relation to your request to speed up our response.

NOTIFICATION OF CHANGESWe reserve the right to amend this Website Privacy Notice from time to time by updating this Website Privacy Notice. If we decide to change our Website Privacy Notice, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the Website Privacy Notice under which the personal information was collected.

CONTACT US

If you have any questions or concerns about this Privacy Notice or to exercise any of your rights hereunder, please contact privacy@springcoast.com.

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal data has been processed by us as described in this Website Privacy Notice under EU and UK Privacy Laws, in the first instance please contact us directly at privacy@springcoast.com. Alternatively, if we are unable to resolve your complaint, you can lodge a complaint under:

the UK GDPR and/or Data Protection Act 2018, please contact the UK Information Commissioner’s Office – https://ico.org.uk/global/contact-us; or
the EU 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.