Declaration

Privacy Policy

OUR COMMITMENT TO PRIVACY

Your privacy is important to Declaration Partners LP and its affiliates (together, “Declaration,” “our,” “us” or “we”). To better protect your privacy, we are providing information explaining our online information practices.

This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use certain information about you through your use of our websites and investor portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). Visitors that are: (a) residents of California should also refer to our California Website Privacy Policy below, or (b) in the United Kingdom or European Union should refer to our GDPR Privacy Notice below, each of which supplements this Website Privacy Policy.

Please read this Privacy Policy carefully. If you do not provide your information for us to use in accordance with this Privacy Policy, then we may not be able to provide our services or products to you and/or you may no longer be able to use the Website fully or at all. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

THE INFORMATION WE COLLECT AND HOW WE USE IT

We may collect various types of information in connection with use of the Website. For example, knowing how users use our website – tracking their movement through this website via “cookies”– helps us improve website design and usefulness. As a result, Declaration’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. Declaration 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” page.

To the extent that you provide us with any personally identifiable information through or in connection with the Website, we may use such information for Declaration’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Declaration, save where the GDPR Privacy Notice applies (in which case it sets out the basis on which we use such personally identifiable information), you consent to Declaration’s use of such personally identifiable information for the purposes described in this Privacy Policy. We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

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 the Website; any transmission of information or data by you to or through the Website is at your sole risk.

You may request to access any personally identifiable information we have about you by contacting us at 1.833.463.0211.

CAPACITY

You represent to Declaration that you have the authority to use the Website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit users of the Website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18. If we learn we have collected or received personal information about an individual under the age of 18, we may be required or otherwise take steps to delete that information or obtain the consent of a guardian.

COOKIES

Information regarding how you access the Website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected using cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where we use cookies that are not necessary for the functioning of the website (for example, for use in relation to marketing and advertising), we will ask you to consent to their use. You may opt-in or opt-out of accepting cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of 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 may access any personally identifiable information we have about you by contacting us at 1.833.463.0211.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review this Privacy Policy regularly. If we decide to change this Privacy Policy, 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 information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of this Privacy Policy under which the information was collected. 

MISCELLANEOUS

Please also see our Terms of Use, which apply to your use of the website.

CALIFORNIA WEBSITE PRIVACY POLICY

This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. 

Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

WHAT DOES THIS WEBSITE PRIVACY POLICY APPLY TO?

This Privacy Policy applies solely to your interactions with us through the Website. If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice, and that notice will govern that personal information.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We collect limited types of personal information through 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 collect from individuals on the Website may include the following:

  • Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
  • Other customer records, such as telephone number and personal information provided in connection with obtaining access to any registered user features of the Website;
  • Any other information that you provide to us via the Website, such as commercial information (including financial data); and
  • Internet or other electronic network activity information, such as information regarding your use of our Website (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.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?

In connection with forming and operating the Website, we may collect and maintain your nonpublic personal information from the following sources:

  • Information provided directly through your communications with us in connection with the Website; and
  • Information captured automatically by us in connection with your use of the Website, 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 purposes:

  • To perform services for you.
  • To improve the Website and the products and services that we offer.
  • To communicate with you, including responding to requests for information submitted by you through the Website.
  • To keep a record of your relationship with us.
  • To audit and verify the quality and effectiveness of our services and compliance.
  • To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
  • To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

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.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We do not sell any of the personal information we collect about you to third parties.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “WHAT INFORMATION DO WE COLLECT ABOUT YOU?”

We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We consider the protection of sensitive 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 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.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. 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 share 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 yes, the categories of personal information that each recipient obtained.

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.

Contact us

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 at the following toll-free number: 1.833.463.0211; or call Leigh Rovzar at 212.321.4038.

Email us at the following email address: lrovzar@declarationpartners.com

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 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.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline.
But in certain cases, additional time might be required. Please contact us at the email address above with any questions about this California Website Privacy Policy.

GDPR PRIVACY NOTICE

OUR COMMITMENT TO PRIVACY

Your privacy is important to Declaration LP and its affiliates (together, “Declaration,” “our” or “us,” “we”). To better protect your privacy, we are providing information explaining our online information practices.

In this GDPR Privacy Notice, “European Data Protection Legislation” means all applicable laws relating to the protection of personal data in force from time to time in the EU or the UK, including (without limitation): Regulation (EU) 2016/679 (the “EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland, the Privacy and Electronic Communications (EC Directive) Regulations 2003, and any other legislation which implements any other current or future legal act of the European Union or the United Kingdom concerning the protection and processing of personal data (including any national implementing or successor legislation), and including any amendment or re-enactment of the foregoing.  The terms “controller”, “processor”, “data subject”, “personal data” and “processing” in this GDPR Privacy Notice shall be interpreted in accordance with the European Data Protection Legislation.  

This GDPR Privacy Notice applies if and to the extent that the European Data Protection Legislation applies to our processing of personal data collected by or provided to us through your use of our Website and supplements the Privacy Policy above (in the event of a conflict, this GDPR Privacy Notice shall take precedence). If you provide personal data to use through another means (e.g., as an employee or seeking employment or pursuant to a services agreement) you will receive a separate privacy notice or agreement, and that notice or agreement will govern our processing of that personal data.

For the purposes of European Data Protection Legislation and this GDPR Privacy Notice, Declaration will be a controller of any personal data collected by us. If this GDPR Privacy Notice applies, such visitors (as data subjects) have certain rights with respect to such personal data, as outlined below.   If you have any questions regarding our use of your personal data, or this GDPR Privacy Notice, please contact us at 1.833.463.0211. 

THE PERSONAL DATA DO WE COLLECT ABOUT YOU

We will collect and process the types of personal data described in the Website Privacy Policy and California Website Privacy Policy above. We do not collect any special categories of personal information 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, etc.). Nor do we collect any information about criminal convictions and offences.

HOW WE OBTAIN YOUR PERSONAL INFORMATION

We will collect your personal data either through you directly providing such data to us in your electronic communications with us via the Website, or through our 

use of various technologies, including cookies, to monitor your use of the Website.

WHY WE USE YOUR PERSONAL INFORMATION

We will process your personal data for the following purposes in reliance on the following legal bases under the European Data Protection Legislation:

Purpose Legal Basis
To provide you with the services or products you have requested. Contractual necessity
To keep a record of your relationship with us. Legitimate interest
To verify your identity. Legal requirement
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to. Legitimate interest
Fraud and abuse prevention. Legitimate interest
Litigation management and conducting internal audits and investigations. Legitimate interest
To administer and protect our business and Website. Legitimate interest
To make suggestions and recommendations to you about goods or services that may be of interest to you. Legitimate interest

No automated decision-making, including profiling, is used when processing your personal information. 

Failure to provide certain personal data may mean that we cannot provide our services or products to you and/or that you may no longer be able to use the Website fully or at all. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

MARKETING

We may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in or opt-out of receiving any such direct marketing communications by contacting us at 1.833.463.0211.

SHARING AND TRANSFER OF PERSONAL DATA

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 GDPR Privacy Notice, including professional advisors, CEOs and CEOs-in-Training, recruitment firms, consultants, placement agents and data hosting providers. We seek to ensure that anyone who provides a service to, or for us, involving the processing of your personal data enters into an agreement with us and meets our standards for data security. To the extent that we transfer your personal data to countries outside of the UK or EEA, such transfers will only be made in accordance with the European Data Protection Legislation. For further information about the safeguards/derogations used, please contact us at 1.833.463.0211.

We reserve the right to disclose your personal data as required by applicable 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 on the basis of our legitimate interest.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the personal data we have about you is protected to the extent possible from unauthorised access and improper use. 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.

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.

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 the Website; any transmission of information or data by you to or through the Website is at your sole risk.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this GDPR Privacy Notice, unless a longer retention period is required by applicable law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact us at 1.833.463.0211.

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 us at 1.833.463.0211. Your rights in respect of the personal data processed by us under this GDPR Privacy Notice are:

  • 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 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 applicable law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your 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 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, 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 CHANGES

We reserve the right to amend this GDPR Privacy Notice from time to time by updating this GDPR Privacy Notice. If we decide to change our GDPR Privacy Notice, we will post those changes so our users are always aware of what personal data 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 personal data collected as described in this GDPR Privacy Notice only in accordance with this GDPR Privacy Notice.

CONTACT US

If you have any questions or concerns about this GDPR Privacy Notice, please contact us at 1.833.463.0211.

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.