PRIVACY POLICY

Advent International Corporation

This Privacy Policy was last updated on, and effective as of August 1, 2020.

1. About this policy

1.1 This privacy policy explains how Advent International Corporation (“Advent”, “we”, “us” and/or “our”) uses personal data and other information that Advent collects in connection with visitors’ (“you”, “your”) use of our website and other interactions with us and our staff.

1.2 Where we refer to “personal data” in this policy, we mean any information relating to (whether directly linked to or reasonably capable of being linked to) an identified or identifiable individual, or household, including but not limited to names, email addresses, phone numbers and online identifiers.

2. Who’s responsible for your personal data?

2.1 Advent International Corporation is the data controller of your personal data. This means that we determine how, and for what purposes, we use your personal data.

3. What personal data do we collect and receive, from where do we collect it, how do we use your personal data, and with whom do we share it?

4.1 We collect or hold various categories of personal data, which we identify below in the first two columns.  For each, we identify the business or commercial purposes for which the data is collected (in the fourth column); categories of sources from which information is collected (in the fifth column), and the categories of third parties with whom we may share the information (in the sixth column).  We may have collected each of the personal data categories identified in the first column below in the past 12 months.  We may have shared personal data with the categories of recipients identified in the sixth column below in the past 12 months.

Category Examples Business or Commercial Purposes for Collection Sources from Which Data Collected Third Parties to Whom Data May be Disclosed
Identifiers

&

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Your full name and contact details (email address, phone number, postal address, and country of residence, if you contact us via the contact information listed on the website)

Information obtained during due diligence of potential targets may include your contact details, date of birth, ID data, details of your financial information and a proposed investment (where relevant) and various other necessary personal information

Information obtained in relation to candidates for employment with us or our affiliates, including education and employment history, financial information (e.g. salary and bank details), social security number, ID number 

Evaluating inquiries and proposed investments on behalf of the funds that we advise

Other business purposes identified below in item 4.1

You might provide contact details to us, including when you contact us via the contact information listed on our website or apply for a job with us 

We may receive due diligence information from a third party, for example, a law firm, who collects personal data from you and passes it on to us where we are conducting due diligence in relation to a transaction, or a recruitment agency. Where this is the case, the third party is responsible for informing you that they have shared your personal data with us, directing you to this policy and obtaining any relevant consents from you to ensure you are happy with the ways in which your personal data will be used

We may collect information about candidates for employment from online sources, such as job boards or online CVs

Professional firms that assist us in evaluating investments and other business transactions

Professional firms that assist us with auditing and other aspects of our internal operations

Third party service providers, such as recruitment and HR consultants 

Protected classification characteristics under California or federal law Age (if 40 years or older), sex, citizenship Other business purposes identified below in item 4.1 You might provide protected characteristics to us, including when you contact us via the contact information listed on our website

We may receive due diligence information from a third party, as explained above

Professional firms that assist us in evaluating investments and other business transactions

Professional firms that assist us with auditing and other aspects of our internal operations

Other recipients identified in item 4.2 below

Commercial information Information obtained during due diligence of potential targets may include your contact details, date of birth, ID data, details of your financial information and a proposed investment (where relevant) and various other necessary personal information Other business purposes identified below in item 4.1 We may receive due diligence information from a third party, as explained above Professional firms that assist us in evaluating investments and other business transactions

Professional firms that assist us with auditing and other aspects of our internal operations

Other recipients identified in item 4.2 below

Internet or other similar network activity Details about the browser, device and Internet connection that you use when you browse our website, technical information, including your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Our website also stores small text files on your device that identify your browser. See ‘Cookies and other tracking technologies’ below for more details

As well as the technical information above, we collect information about your visits to our websites, including the full web addresses that you access, your path of clicks through and from our site (including date and time and whether you used a search engine), download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page

Other business purposes identified below in item 4.1 Your device provides this information when you browse our website (whether or not you have accepted cookies)

When you visit our website and use Advent services that require us to identify you—Cookies can also be set when you open our emails

Technical and data analytics providers that assist us in maintaining our website and understanding traffic to and within our website

Other recipients identified in item 4.2 below

Professional or employment-related information Information obtained during due diligence of potential targets may include your contact details, date of birth, ID data, details of your financial information and a proposed investment (where relevant) and various other necessary personal information Other business purposes identified below in item 4.1 We may receive due diligence information from a third party, as explained above Professional firms that assist us in evaluating investments and other business transactions

Professional firms that assist us with auditing and other aspects of our internal operations

Other categories of recipients identified in item 4.2 below

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

 

3.2 We have not (within the past 12 months) sold any personal data.

3.3 We will store your data using various technologies including centralized file servers, centralized databases, or file systems of individual computer users, in each case either residing on Advent’s own systems or on computer systems leased by Advent (such as cloud systems).  In some cases, personal data may be stored in paper records, particularly as required by various laws pertaining to financial market participants.

4. Other ways we may use or share your personal data and who we share it with

4.1 Aside from the specific uses described above with respect to particular categories of personal data, we also may use any of your personal data identified above for the following general purposes:

(a) For corporate transactions

We may use any personal data that we hold about you in the course of corporate transactions such as the purchase or sale of assets.

(b) For marketing purposes

If you express an interest in relation to certain investments or our broader business activities, we may contact you to provide you with information about events or investments that we think you might be interested in.

(c) To develop and grow our business

We may use the personal data you share when contacting or meeting with our staff to analyze certain information about those interactions. For example, we may analyze who you contacted at Advent and who you meet with (including by sharing certain of your communications with us with a third party service provider for that purpose). We use this personal data to help us consider how best to strengthen our relationships with key contacts, and to develop and grow our business.

We also collect personal data for the purpose of identifying and hiring talent.

(d) For compliance with our legal obligations

We are sometimes subject to certain legal requirements to collect, retain and disclose your personal data when officially requested to do so, for example for performing identity checks, including for anti-money laundering and ‘know your customer’ compliance, and in relation to criminal investigations.

4.2 Aside from the disclosures to specific third parties described above with respect to particular categories of personal data, we may share your personal data for the purposes listed above with the following recipients:

(a) Parties involved in business transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, any change in control, dissolution or similar event, personal data may be part of the transferred assets or otherwise disclosed in the course of due diligence for the transaction.

(b) Our affiliates

We may share your personal data with our affiliates for purposes consistent with this privacy policy.

(c) Our agents, business partners, licensors and service providers

Advent, like many businesses, sometimes hires or works with other companies to perform certain business-related functions. When we employ or work with another company to perform a function of this nature, we provide them with only the information that they need to perform their specific function and restrict their use of the information.

(d) Government authorities, law enforcement agencies, courts and parties to litigation

Advent may disclose your personal data if required to do so by law or in the good-faith belief that such action is necessary to: (i) comply with a legal obligation; (ii) protect and defend Advent’s rights or property; (iii) act in urgent circumstances to protect the personal safety of users of our website or the public; or (iv) protect against legal liability.

5. Direct marketing

5.1 We may contact you for marketing purposes, including to tell you more about certain events or to share news we believe you will be interested in. You’re always in control of the emails that you receive and you can update your preferences or opt out at any time by following the links in our emails or by contacting us.

6. Cookies and other tracking technologies

6.1 We use cookie data and other technologies to collect information on our web pages for a variety of purposes, such as to improve the design and content of our website and to enable us to provide a more personalized experience when you browse the Internet to our website. A cookie is a piece of information that the computer that hosts our website gives to your browser when you access the site. We use cookies to recognize repeat users and to allow us to observe behavior and compile aggregate data in order to improve the site.

6.2 Most web browsers have an option that allows you to turn off all cookies or have your computer inform you each time that a request to place a cookie is being made. If you turn cookies off (or refuse to accept a request to place a cookie), you may not have access to some features on our websites and some of our services. We also might not be able to remember your preferences without using cookies.

6.3 Some web browsers also have an option that allows you to send “Do Not Track” requests to websites.  Advent does not respond to Do Not Track (DNT) signals.

6.4 Further, our website contains some technologies that may allow other businesses to collect information, such as your device’s IP address or other online identifying information, directly from you when you visit our site.  

7. International transfers of personal data

7.1 Advent is a global business, and we may transfer personal data outside the UK and the European Economic Area (EEA). Where required to do so by applicable data protection law, we use the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your personal data that is transferred outside the EEA.

8. Legal basis for our use of your personal data and legitimate interests

8.1 Legal bases – To the extent that European data protection law applies to our data processing activities, we only process your personal data where at least one of the following applies:

(a) you’ve consented to the processing of your personal data for a specific purpose – we process your sensitive personal data and send you electronic direct marketing communications based on your consent for us to do that;

(b) the processing is necessary for us to perform our contract with you (including in relation to investments or the operation of portfolio companies) or for us to take steps at your request before we enter into the contract;

(c) where we need to process your personal data to comply with a legal or regulatory obligation that we’re subject to;

(d) where we need to process your personal data to protect your vital interests (or somebody else’s); or

(e) where the processing is necessary for the purposes of our legitimate interests or a third party’s legitimate interests.

8.2 Legitimate interests – We rely on several legitimate interests for using and sharing your personal data, including:

(a) improving our services;

(b) marketing activities;

(c) identifying and pursuing new ways to develop and grow our business, including identifying and hiring talent; and

(d) operating and administering our portfolio companies and other investments.

9. Data retention

9.1 We retain your personal data only for as long as necessary: (i) for the purposes set out in this policy; (ii) to provide our services to you; (iii) to comply with our legal obligations; or (iv) to comply with our usual business data retention policies.

10. Your rights

10.1. To the extent that European data protection law (“GDPR”) or the California Consumer Privacy Act (“CCPA”) applies to our processing of your personal data, you may have various rights with respect to your personal data.  Subject to certain exceptions under the applicable law, you may ask us to:

(a) provide you with access (under GDPR) or disclose to you (under CCPA) the personal data that we collect, hold, use, disclose, or sell about you;

(b) correct your personal data (under GDPR);

(c) erase your personal data (under GDPR and CCPA);

(d) restrict our processing of your personal data (under GDPR);

(e) object to our processing of your personal data (under GDPR);

(f) object specifically to us using your personal data for profiling for direct marketing purposes (under GDPR);

(g) provide a copy of your personal data in an easily accessible format (under GDPR); 

(h) where you have specifically consented to our use of your personal data, to withdraw that consent at any time (under GDPR); and

(i) to exercise your privacy rights conferred by the CCPA without receiving discriminatory treatment for the exercise of those rights (under CCPA).

10.2 To exercise the rights above, you can:

(a) email us at privacyrequest@adventinternational.com;

(b) call +1-844-858-2283 (toll free); or

(c) fill out the online form at https://www.adventinternational.com/privacy-policy/requestform/.

10.3 In exercising your rights through one of these methods, you may need to provide certain information so that we can verify your identity.  If you are making a request under the CCPA, then we may require you to provide us with particular pieces of identifying information that match information that we maintain about you. We may then undertake various activities to verify your identity that are appropriate to mitigate the risk of your data being provided to a third-party without your consent.  For example, we may ask you to confirm your identity by responding to communications that we send to your email address or phone number already on file, or we may ask you to verify your identity through a third-party service.

10.4 If you are making a request under the CCPA, you may designate an authorized agent to exercise your rights on your behalf.  In such a case, we may require that you provide the authorized agent written permission to do so; and verify your own identity directly with the business, except where an authorized agent has a power of attorney pursuant to California Probate Code sections 4000 to 4465.

11. Changes to our privacy policy

11.1 We may change this privacy policy from time to time without prior notice. Any changes we may make to our privacy policy in the future will be posted on this page.

12. Exclusions

12.1 This policy applies only to this website. Our website may contain links to other sites not operated or controlled by Advent. The policies and procedures we have described here do not apply to these third party sites. The links from our website do not imply that Advent endorses or has reviewed any third party sites. We suggest contacting those sites directly for information on their privacy policies.

13. Other terms and conditions

13.1 Your access to and use of this website is subject to the Terms and Conditions of Use, available at http://www.adventinternational.com/terms-conditions.

14. Contact us and complaints

14.1 If you have any questions, comments or complaints about any aspect of this policy or Advent’s privacy policies and practices, please contact us at +1-844-858-2283 (toll free) or privacyrequest@adventinternational.com.

14.2 To the extent that European data protection law applies to our processing of your personal data, you have the right to make a complaint about how we process your personal data to the relevant supervisory authority.

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