What Information We Collect
We may collect and process the following personal data about you:
- Identifiers such as name, postal address, email address, telephone number and other contact information;
- Internet or other network activity and technical information: for example, browsing or search history, information regarding your interaction with sites and related applications, IP addresses and online identifiers such as cookies;
- Mailing list data such as marketing and communications preferences and interests;
- Audio, electronic, visual or similar information, including photographs and CCTV footage;
- Physical access data relating to details of your visits to our offices;
- Sensitive personal information, such as health information, of visit
- Commercial information and financial information;
- Professional information: for example, employment details, education information, occupational history or business relationships; and
- Other information you provide, or which may be incidentally processed, when you contact us.
We may also collect personal data from other sources, such as other companies providing services to us. Some third-party sources may include publicly available sources of information.
How Information is Used
We utilize the aggregate Website usage information described above to better understand how visitors are utilizing our Website in order to enhance the Website experience.
We may use your personal data:
- for our legitimate business interests such as to operate, manage, develop and promote our business, sites and premises, to monitor access to the Website and to protect our business from fraud, money laundering and other financial or business crimes, and to screen, identify and evaluation candidates for job positions, including conducting background checks;
- to send you direct marketing in relation to our services and/or other activities such as events; and
- to comply with our legal and regulatory obligations and bring and defend legal and/or regulatory claims.
In the regular course of business, we do not disclose any information collected from the publicly available areas of our Website to any parties outside of TCV other than service providers, professional advisors and affiliates. Personal data otherwise voluntarily provided by you (e.g., via email) may be disclosed to third parties, service providers, professional advisors and affiliates in order to facilitate our services and perform functions on our behalf.
Any information collected through our Website or that you otherwise provide to us may be disclosed to other recipients in connection with a court order, subpoena or government inquiry or similar request or proceeding or as otherwise required by law.
We may also disclose your personal data to 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.
To the extent that we request personal data from you and you refuse to communicate that personal data to us, this may affect our ability to maintain a business relationship with you or to comply with our legal obligations.
Our Website uses “cookies” to facilitate your ongoing access to and use of our Website, and to help us in the ongoing maintenance of our Website. Cookies are small text files that may be placed on your browser when you visit our Website. For instance, when you return to the Website after logging in, cookies provide information to the Website, including personal information, so that the Website will remember who you are.
Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s HELP menu to learn your options with respect to cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of our Website smoother, and some of our services may not function properly. You may at any time delete any cookies by using the relevant option of your Internet browser or by deleting the cookies on your hard drive.
If you continue to use the Website with a browser set to accepting cookies, we will assume that you accept receipt of all cookies coming from the Website.
Do Not Track
We employ organizational, physical, technical and procedural safeguards that are designed to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use. However, no data transmission over the Internet can be guaranteed to be secure or hacker-proof. TCV cannot ensure or warrant the security of any information you submit via the Website or otherwise, and you do so at your own risk. Please consider this when you choose to submit information to us via the Website or otherwise.
Visitors Residing Outside of the United States and Consent to Transfer
Visitors who use our Website and reside outside of the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Please see information below regarding transfers of personal data if you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”). If you are located outside of the United States, please be aware that any information you provide to us will be transferred and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.
Transfers of Personal Data Outside the EEA or the UK
If you are in the EEA or the UK and transfer your personal data to us directly, you will be transferring such data voluntarily and entirely at your own discretion to our offices in the United States. The United States does not have data protection and privacy laws that provide the same degree of protection as those in the EEA or the UK.
If we were to process your personal data in the context of an establishment in the EEA or the UK and transfer your personal data to a recipient outside of the EEA and/or the UK, we would only do so pursuant to a valid transfer mechanism such as:
- an adequacy decision by the European Commission (or equivalent);
- data transfer agreements and/or safeguards using terms approved by the European Commission (or equivalent); and/or
- other valid transfer safeguards in accordance with applicable data privacy law.
For further information about such safeguards, please contact us using the information below.
How Long Do We Retain Personal Data?
Subject to applicable law, we retain your personal data (as the case may be) for as long as it is required for the purpose for which we collected it, or for such period as is required by or to allow us to comply with legal or regulatory obligations which apply to us.
Rights Under the GDPR
Where the EU General Data Protection Regulation 2016/679 (the “GDPR”), the UK GDPR (as such term is defined in the UK Data Protection Act 2018) and/or substantially similar law applies, you may be entitled to the following rights:
- a right to know what personal data we process and a right of access to such personal data;
- the right to request any incomplete or inaccurate personal data to be corrected;
- the right to object to our processing of your personal data;
- the right to request we delete your personal data in certain circumstances, including where you believe that it is no longer necessary for us to hold your personal data, where we are processing your personal information on the basis of legitimate interests and cannot demonstrate an overriding legitimate ground for the processing, or where you believe the personal data we hold about you is being unlawfully processed by us;
- the right to request we restrict processing of your personal data in certain circumstances—i.e., where you believe the personal data is inaccurate, and while we verify accuracy, where we want to erase your personal data as the processing is unlawful but you want us to continue to store it, where we no longer need your personal data for the purposes of our processing but you require us to retain it for the establishment, exercise or defence of legal claims, or where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection; and
- a ‘data portability’ right to require us to transfer your personal data to you or to a third party in a structured, commonly used and machine-readable format.
We do not generally rely on your consent to process personal data, but to the extent we do and you no longer wish to provide such consent, you can contact us to let us know that you withdraw consent. This does not affect personal data processed prior to your withdrawal of consent.
You also have the right to lodge a complaint about our processing of your personal data with the relevant body regulating data protection in your country. In the European Economic Area, details of the relevant bodies are available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. In the UK, the relevant authority is the Information Commissioner’s Office: https://ico.org.uk/make-a-complaint.
What information do we collect about you?
We collect limited types of personal information through our 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:
- Category A: Identifiers, such as name, contact details and address (including physical address, email address and IP address);
- Category B: Other customer records, such as telephone number and personal information provided;
- Category D: Commercial information;
- Category I: Professional or employment-related information;
- Category J: Education information; and
- Category F: 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.
For additional details about the personal information we may collect, please refer to the section titled “What Information We Collect” above.
We do not knowingly collect personal information from anyone under the age of 18.
We do not collect any sensitive personal information from you.
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; and
- information captured on our Website, including registration 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 long do we retain your personal information?
For each of the categories of personal information that we collect (listed above), we retain such personal information only for as long as reasonably necessary to fulfill the purposes we collected it for, including for purposes of satisfying any legal, regulatory, accounting or reporting requirements, unless a longer retention period is otherwise required by law.
How long do we retain 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 our Website and the products and services that we offer and notify you about changes to our products and services;
- to communicate with you, including responding to requests for information submitted by you through our Website;
- to keep a record of your relationship with us;
- to protect the security of and manage access to our physical premises;
- ongoing operations, administrative, accounting, reporting, account maintenance and other processes;
- 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; and
- to 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.
To whom do we disclose your personal information?
We do not “sell” or “share” (as such terms are defined by the CCPA) 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, service providers and other third parties in order to facilitate our services and perform functions on our behalf, 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 disclosed each of the categories of personal information collected in connection with this Website to affiliates and service providers as set forth above in “What Information We Collect”.
We may also disclose your personal information to 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.
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.
Correction Rights: You have the right to request that we correct inaccurate personal information about you.
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 to 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.
Non-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 to you) a different level or quality of service.
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 toll-free at +1 (888) 623-8327
- Email us at email@example.com outlining your request. Be sure to include your contact information.
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 (e.g., the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf if 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.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required (up to 90 days). If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
California’s Shine the Light Law
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits our Website users who are California residents to request and obtain from us a list of their personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year, and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not disclose any personal information to third parties for their direct marketing purposes.