Effective March 2023
CCMP Growth Advisors, LP (the “Company”, “we”, “us” or “our”) considers privacy to be fundamental to its relationship with you. This Privacy Notice describes how we may collect, use, share and otherwise process personal information we collect through our website at ccmpgrowth.com (the “Site”), as well as information that we may collect via other means, as described below (“you” or “your”).
If you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to the Investor Privacy Notice (as available in our investor portal or otherwise provided to you) for further information about how the Company collects and processes personal information about its current, prospective and former individual investors.
I. Personal information we collect
“Personal information” is any kind of information that allows us to identify you, directly or indirectly, such as your name, contact details, or address. We may collect and process the following personal information about you:
- Identifiers, such as your name, address, email address and telephone numbers;
- Professional or employment information, such as your job title and place of work;
- Internet or other electronic network activity information, such as your internet protocol (IP) address, login data, unique device identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile device carrier and other technology on the devices you use to access the Site; as well as usage information, such as information about how you use the Site and our products and services, referring/exit web pages, date/time stamps, error logs, and the frequency of your use of the Site; and
- Marketing and communications information, such as your preferences in receiving marketing communications from us.
We also collect, use and share aggregated information such as statistical or demographic data for any purpose. This information could be derived from your personal information but will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect information with your personal information so that it can directly or indirectly identify you, we treat the combined information as personal information which will be used in accordance with this Privacy Notice.
II. How we collect your personal information
We collect personal information from you via the following:
- Personal information you provide to us
- Forms you complete (or which are completed by your authorized representatives on your behalf) on the Site or otherwise; and
- Your correspondence and interactions with us, including by letter, email and telephone.
- Personal information collected from third parties
We may collect personal information about you from third parties, such as business partners, vendors, or from publicly available information. The conditions under which we may obtain such information are governed by the third party source.
- Information collected automatically
We may automatically collect certain information about the devices you use to access the Site, as well as information on how you interact with the Site, through cookies, web server logs, and other similar tracking technologies.
Cookies and other data collection technologies
We may collect information about your use of the Site through cookies, web server logs, and other similar tracking technologies.
“Cookies” are a feature of web browser software that allows web servers to recognize the computer used to access a website. They are small text files that are stored by a user’s web browser on the user’s hard drive. Cookies can remember what information a user accesses on one website to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transactions on related websites. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies last longer and are used to recognize your computer when you return to the Site. Cookies are designed to make your online experience easier and more personalized. They can only be read by the server that placed them, and are unable to execute any code or virus.
Web server logs are files that store the activity on a certain website.
You can change your browser settings to notify you of the cookies being set or updated, and to block cookies. Please note that if you have turned off all cookies, some features of the Site may not be available to you or otherwise function as intended.
We also may include tracking pixels and web beacons in email messages, newsletters, and other electronic communication. They help us to determine whether a message has been opened and to analyze and personalize our interactions with you. Instructions on how to unsubscribe are included in each email.
We currently only use “Analytics” cookies on the Site, which may include third party analytics providers such as Google Analytics.
These cookies collect anonymous statistics on visitors to the Site, how they accessed it, how much time they spend there, and which pages they visited. This information helps us understand how visitors use our services, and to customize the Site and our services for you. The functionality of the Site is not impacted by the rejection of such cookies.
Most web browsers automatically accept cookies. You can, however, change your browser to prevent this or to notify you each time a cookie is set. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.
In addition to electing the option to reject or disable cookies provided on the Site, you can also prevent Google Analytics from using your information by downloading and installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout).
“Do Not Track” Browser Settings
We do not currently use technology that recognizes “do not track” signals from your web browser.
III. How we use your personal information
We will only use your personal information when the law allows us to. Any of the information we collect from you may be used in one of the following ways:
- Where the processing is necessary for us to enter into or to perform a contract with you, or to take steps at your request prior to entering into a contract – for example, to provide information you have requested or to respond to your questions;
- Where necessary for the purposes of the Company’s legitimate interests, including to operate and facilitate our business and services, communicate with you, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain the Company’s core records, protect the Company’s rights and interests, ensure the security of the Company’s assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, and enforce our terms and conditions; and
- Where required by applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions;
- Where the processing is necessary for the establishment, exercise or defense of legal claims.
In some circumstances, we may process your personal information where we have received your consent. For example, depending where you are located, in order to send you marketing materials. Where processing is based on your consent, you have the right to withdraw that consent at any time.
IV. How we protect your personal information
We are committed to maintaining the confidentiality, integrity and security of your personal information and take precautions to protect such information. These precautions include the adoption of certain physical, electronic, and procedural safeguards and procedures designed to maintain and secure your personal information from inappropriate disclosure in accordance with applicable laws and regulations.
We restrict access to personal information to those employees and agents of the Company who need to know that information in order to provide the Company’s services. We may disclose such information to our service providers (including financial, technical, marketing and professional service providers and consultants) and financial institutions that provide services to the Company. We require such third party service providers and financial institutions to protect the confidentiality of your personal information and to use the information only for purposes for which it is disclosed to them.
V. When we disclose your personal information
We do not disclose any personal information to anyone other than our affiliates, service providers and relevant counterparties without your consent, or as required by applicable law or regulation. This means that we may disclose your personal information to other third parties, including:
- Any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over the Company or its affiliates, if (i) the Company determines that such disclosure is necessary or advisable pursuant to or in connection with any U.S. federal, state or local, or non-U.S., law, rule, regulation, executive order or policy, including without limitation any anti-money laundering law and the USA PATRIOT Act and (ii) such disclosure is not otherwise prohibited by law, rule, regulation, executive order or policy;
- Persons acting in a fiduciary or representative capacity on behalf of an investor, such as an IRA custodian or Trustee of a grantor trust; and
- Certain other persons to the extent authorized by you.
On all occasions when it is necessary for us to share your personal information with other parties, we will require that such information only be used for the limited purpose for which it is shared and will advise such third parties not to further share your information with others except to fulfill that limited purpose.
We do not disclose personal information except as may be required or permitted by law, rule or regulation. We may disclose for a business purpose, and have disclosed in the preceding twelve (12) months, personal information, including contact information, employment information, identification information, background information and financial information to third parties, as listed above.
We do not sell personal information obtained about you to any third parties, and have not done so in the twelve (12) months preceding the effective date of this policy. We may aggregate survey responses for publication. However, this will not include any non-public personal information or any information identifiable to a particular Site user.
VI. How we transfer your personal information
Your personal information may be collected in, transferred to, stored or otherwise processed in a country other than the one in which it was collected, including the United States. Such country may not or may not be deemed to provide the same level of protection for personal information as your jurisdiction.
When we transfer personal information internationally, and to the extent required by applicable data protection laws, we rely on appropriate or suitable safeguards, including:
- Where the relevant country or recipient has been deemed to provide an adequate level of protection for your personal information by relevant authorities;
- Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards;
- Obtaining your consent to transfer personal information after first informing you about the possible risks of such a transfer;
- Transferring the personal information because it is necessary for the performance of (or to enter into) a contract between you and the Company, or because the transfer is necessary for the performance of a contract between the Company and a third party, and the contract was entered into in your interest; and
- Transferring the personal information because it is necessary to establish, exercise or defend legal claims.
For more information on the safeguards we have in place, please contact us using the details below.
VII. Retention of your personal information
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Notice, or as long as we are legally required or permitted to do so. Under certain circumstances, you may have the right to have your personal information erased.
When deciding how long to retain your 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 personal information, the purposes for which we process your personal information described above and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
VIII. Third party links
The Site may contain links to third party websites, products and services. These third party websites and services have separate and independent privacy policies, which we encourage you to read. We have no responsibility or liability for the content and activities of such linked sites. However, we want to protect the integrity of our Site and thus welcome any feedback you may have about third-party sites we link to.
IX. Children’s Privacy
The Site is not directed toward children under the age of 18. We do not promote our products or services online to minors, and we do not intentionally collect any personally identifiable information from any person under 18. If we become aware of having collected personal information from children under the age of 18 without valid consent from their respective parents or guardians, we will delete is as soon as practicable.
X. Changes to your personal information
You are not required to supply any of the personal information that we may request, except where such information is necessary for the performance of (or to enter into) a contract with you or is otherwise required by applicable law. However, failure to do so may result in our being unable to accept your business or provide services to you. We will make every effort to ensure that all information that we hold about you is accurate, complete and up to date. You can help in this regard by promptly notifying us at the address listed below if there are any changes to your personal information.
XI. Changes to this Privacy Notice
We may update this Privacy Notice periodically, without prior notice, so please review it frequently. If we decide to change our Privacy Notice, we will post those changes on the Site so that you are aware of what kinds of personal information we collect, use, share and otherwise process.
XII. Privacy rights
We are committed to providing individuals with reasonable and appropriate access to their personal information. If you believe that we are processing personal information about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as where the request is manifestly unfounded or excessive. We are happy to correct inaccurate data or delete information that is not appropriate to retain. Please also let us know if you have any questions, concerns, disputes, or issues.
Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority. We are always open to dialogue to resolve issues short of formal disputes. If your concerns cannot be resolved, we can enter into appropriate third- party neutral dispute resolution. If you need to reach us about a privacy or data protection issue, please contact us using the details below.
If you wish to exercise any of these rights please email GrowthIR@ccmpcapital.com or call us at 1-(866) 456-1168. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your personal data only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.
The California Consumer Privacy Act (“CCPA”) prohibits covered businesses from discriminating against you for exercising applicable CCPA rights.
If you make a request related to personal data about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law
XIII. Contacting Us
If you have any questions or concerns about this Privacy Notice, please contact us at:
CCMP Growth Advisors, LP
1 Rockefeller Plaza, 16th Floor
New York, New York 10020 Phone: 1-(866) 456-1168