Privacy Notice

Our commitment to privacy

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

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.transformcap.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 Transformation Capital 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 if you are based in the United Kingdom or the European Union, you should also refer to the section headed “Additional information for visitors in the United Kingdom and the European Union”, for a description of additional information and rights that you may have. If you are a resident of California, you should also refer to the section headed “Notice to California consumers of certain rights under the CCPA”, for a description of additional rights specific to California residents.

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;
• 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 and profile data. Please see below for a more extensive list of the types of personal data we may collect: 

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 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 Website, 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 Website 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)):

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 by us 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 contact@transformcap.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 Website Privacy Notice. 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, 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 contact@transformcap.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 contact@transformcap.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 to websites instructing them not to place cookies on the device running that browser. Our website accessible at www.transformcap.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 or features of our Websites.

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

Additional information for visitors in the United Kingdom and the European Union

This section 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).

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”), Transformation Capital 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 contact@transformcap.com.

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”.

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 contact@transformcap.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.

Should you wish to lodge a complaint with regards to how your personal data is processed by us as described in this Website Privacy Notice under the EU and UK Privacy Laws, in the first instance please contact us directly at contact@transformcap.com. Alternatively, and if we are unable to resolve your complaint, you can lodge a complaint with your local supervisory authority which, in the UK, is the Information Commissioner’s Office (please visit:https://ico.org.uk/global/contact-us).

Notice to California consumers of certain rights under the CCPA

This section outlines 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 section 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 section is otherwise set forth above in the Website Privacy Notice. 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.

Categories of Personal Information We Collect: We have collected some or all of the following categories of personal information from individuals within the last twelve (12) months: 

We have collected other personal data from companies, investors, and team members, but that is all captured during the deal process, fundraises, recruiting processes, our vendors, and our third party managed websites that we do not control. 

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; 
• As reasonably necessary and proportionate to ensure the physical safety of natural persons; 
• 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); and
• To perform services on behalf of our business.

Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:

• performing services to you, including but not limited to: 
• the administrative processes (and related communication) in preparing for the admission of investors to the fund(s); 
• ongoing communication with potential investors, their representatives, advisors and agents (including the negotiation, preparation and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements; 
• the performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC and other related laws and regulations) in assessing suitability of potential investors in the applicable fund; 
• ongoing operations, administrative, accounting, reporting, account maintenance and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions and financing;
• keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising; 
• administering, managing and setting up an investor’s account(s) to allow such potential investor to purchase its holding (of shares) in the fund(s);
• facilitating the execution, continuation or termination of the contractual relationship between a investor and the general partner and/or the fund(s);
• facilitating the transfer of funds, and administering and facilitating any other transaction, between a potential investor and the fund(s);
• auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance; 
• maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; 
• enabling any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s or the investment fund/limited partnership’s rights or obligations to evaluate proposed transactions;
• facilitating business asset transactions involving the investment fund/limited partnership or investment fund/limited partnership-related vehicles; and
• complying with U.S., state, local and non-U.S. laws, rules and regulations.

We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.

Disclosure of Information: We do not sell or share (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties. In the preceding twelve (12) months, we have not sold or shared any of the personal information we collect about you to third parties. We do not disclose any non-public personal information about you to anyone, except as permitted or required by law or regulation and to service providers. 

Within the last twelve (12) months, we have disclosed personal information collected from you 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.