INVESTOR PRIVACY NOTICE – KEY PRINCIPLES

As an investor or potential investor in a Hellman & Friedman fund or any of its affiliated parallel funds or alternative investment vehicles, you are entitled to know how we protect your personal data and how we limit its disclosure. Below are the key principles of our Investor Privacy Notice (“Investor Privacy Notice” or “Notice”), which can be accessed on the Hellman & Friedman Investor Portal and is set out in the Appendix hereto. This summary of key principles should be read together with the more detailed Investor Privacy Notice set out in the Appendix. 

The Investor Privacy Notice applies to individuals who are our investors, prospective investors or have been our investors in the past, and to those other persons referred to as “you” in the Investor Privacy Notice. The Investor Privacy Notice describes how we process personal data (also called personal information) received about you in relation to your investment or potential investment, which may include financial or other information about you. Capitalized terms used herein have the meaning given to them in the Investor Privacy Notice.

Personal Data We Collect and Process

We collect personal data about you when you complete the subscription forms and associated documentation and by registering for and accessing our Investor Portal or by communicating with us by phone, e-mail or otherwise, or attending meetings and events hosted or coordinated by us. This information may include, for example, your name, address, social security number, net worth and income or health information.  We may also collect personal information, which may include health information, for health and safety purposes in connection with in-person meetings or events.

Further details of how we collect personal data about you and the types of personal data we may collect and process are set out at Section 3 (What personal data is collected and processed?) of the Investor Privacy Notice.

Purposes of Processing and Disclosure

We process your personal data for the purposes set out in Section 4 (What is the purpose for processing the personal data). By way of summary only, these purposes include:

• To administer your fund interests, manage your subscription, for transfers of interests, maintaining the register of partners and distributions, managing distributions including the allocations of profit and loss between investors, internal audit validations, communications, events, investor relations and more generally performance of services requested by you and operations in accordance with your instructions.
• To conduct Know Your Customer (“KYC”) and/or Anti-Money Laundering (“AML”) and other compliance monitoring, each as required by applicable Law (defined in the Appendix, below) or an industry or internal best practice, and to complete certain transactions or account changes that you request (in relation to which, it may be necessary to provide identifying information to non-affiliated third parties, such as transfer agents, custodians and facilitating brokers in connection with distributions-in-kind).
• For health and safety purposes, where applicable.
• We may disclose your information within the Hellman & Friedman family of affiliated funds or entities so that we can alert you to other partnerships or investment vehicles that we are sponsoring.

In certain instances, we may use non-affiliated third parties (such as brokers, lenders, registered agents or other advisors) to perform services for, or provide funding to, us and, where necessary, disclose your information to them as set out in further detail in Section 6 (To which  third parties will personal data be disclosed?) of the Investor Privacy Notice (and in each case, to the categories of third parties set out therein). In all such cases, we provide the third party with only the information necessary to carry out its assigned responsibilities and only for that purpose. Further, we require these third parties to treat your non-public information confidentially.

Where any member of the Hellman & Friedman Group is under an obligation to do so pursuant to Law (defined below) or when, in our judgment, it is prudent to do so, it will disclose your personal data to regulators, courts, the police, tax authorities or other governmental authorities, or in the course of litigation or other proceedings or investigations, actual or threatened. In some cases, it may not be reasonably practicable or possible in accordance with applicable Law (defined below), to notify you in advance about the details of such disclosures.

Who Has Access to Your Personal Data

We restrict access to your personal data to those employees, advisors, agents and other persons who need to know that information to enable us to provide our services to you, including to the recipients and for the purposes set out in further detail in Section 6 (Which third parties will personal data be disclosed to?) of the Investor Privacy Notice. To protect your personal data from unauthorized access and use, we use security measures that comply with applicable Law.

We Will Keep You Informed

The Investor Privacy Notice (which replaces all previous statements of our investor privacy policy) may be amended from time to time, at our discretion, and will be available on the Investor Portal or on request by email to [email protected].

Contact Details

For all data privacy inquiries and any questions or concerns you have about the Investor Privacy Notice, please contact the data privacy contacts at Hellman & Friedman at:

             E-mail: [email protected]
             Phone: +1 415 788 5111 (please ask for the Compliance Department)
             Post: Compliance Department, 415 Mission Street, Suite 5700, San Francisco, CA 94105, USA

Appendix
Investor Privacy Notice

1. PURPOSE

2. DATA CONTROLLER CONTACT DETAILS

The General Partners are the initial data controllers in relation to Personal Data relating to the actual or potential Investors (or persons representing such Investors) in Partnerships of which they act as general partner. As described in Section 6 below, the General Partners may share your personal data with other members of the Hellman & Friedman Group, who will process your personal data as an independent controller as described in this Privacy Notice.

Details of the General Partners of the Partnerships comprising any current H&F Funds are available on the Hellman & Friedman Investran DX investor portal or such successor investor portal as the Hellman & Friedman Group may utilize from time to time (such portals the “Investor Portal”).  Alternatively, you may request details of such General Partners by emailing [email protected].

Details of the General Partners of the Partnerships comprising any H&F Funds which are closed for subscription by new investors are set out in the subscription agreements and/or limited partnership agreements, as may be the case, of which existing Investors in such Partnerships (or persons acting on behalf of such Investors) have copies.

For any questions or concerns you have about this Privacy Notice, please contact us at:

             E-mail:    [email protected]
             Phone:     +1 415 788 5111 (please ask for the Compliance Department)
             Post:       415 Mission Street, Suite 5700, San Francisco, CA 94105, USA

3. WHAT PERSONAL DATA IS COLLECTED AND PROCESSED?

For the purposes of this Privacy Notice, the “Investor” is the person or entity that is making, or proposing to make, an investment in a Partnership.   

Where you are an Investor who is an individual, you will provide your personal data by completing the subscription forms and associated documentation and by registering for and accessing our Investor Portal, by communicating with us by phone, e-mail or otherwise, or attending meetings and events hosted or coordinated by us.

Where you are acting on behalf of an Investor (i.e., you are an advisor, employee or contact person of an Investor (or its affiliates) or you are an ultimate beneficial owner of an institutional investor or an advisor, employee or contact person of such ultimate beneficial owner), you and/or the Investor will provide your personal data to us by completing the subscription forms and associated documentation, by accessing our Investor Portal, or by communicating with us by phone, e-mail or otherwise (including through our advisors), or attending meetings and events hosted or coordinated by us.  If you are an institutional investor, our expectation is that you will provide a copy of this Privacy Notice to your employees or other contact persons, whose personal information you disclose to us.

In both cases, we may collect and process some or all of the following personal data (also called personal information) about you:

3.1   Categories of sensitive personal information under the California Consumer Protection Act of 2018, as amended from time to time (the “CCPA”):

• Citizenship – of your directors, officers, owners, beneficial owners, employees, trustees or advisors.
• Government ID —Social Security, driver’s license, passport number including those of your directors, officers, owners, beneficial owners, employees, trustees or advisors;
• Accounts — Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account, e.g., our Investor Portal;
• Race and ethnicity — Racial or ethnic origin, which may be revealed by a Government ID or when disclosed by you voluntarily;
• Communications —mail, email, text messages (including through SMS, WhatsApp and similar channels), calls, voicemail and any other messages communicated to us or otherwise to the extent we have access (including through our Wi-Fi, as applicable), including for the purposes of monitoring or surveillance (where permitted by Law, as defined below and to comply with requirements applicable to the entity with which you have a relationship or to other members of the Hellman & Friedman Group); and
• Health — If attending a Firm event or visiting our offices, vaccination details, requests for reasonable accommodation, allergies, meal preferences and accidents, as applicable.

3.2    Other categories of personal information:

• Identity Information, such as contact and/or personal data such as first name, last name, telephone number, email address, residential address; KYC and/or AML documentation including proof of identity and proof of address (for example, utility bills, bank statements);
• Commercial and Transactional Information, such as information we collect from partnership agreement signature pages, investor questionnaires, subscription agreements and/or other forms and in communications with you, such as net worth and income; history of investments, investment preferences and / or tax position, allocation of interests in any Partnerships and/or allocation of profit or other distributions from such Partnerships; information about your transactions with us or our affiliates, including capital account balances and parties to and terms of such transactions; bank details and wire instructions; information about your transactions with non-affiliated third parties, including information about transfers of your interests in our funds to third parties and parties to and terms of such transactions with third parties;
• Internet or other electronic network activity information: During each of your visits to our Investor Portal we automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and email address;
• Audio, electronic, visual and similar information, through voicemails, email and any video or CCTV recordings;
• Inferences, based on information about an individual to create a summary about, for example, investment interests; and
• Any other personal information disclosed to us.

4. WHAT IS THE PURPOSE FOR PROCESSING THE PERSONAL DATA?

We process your personal data in reliance upon the legal basis or business interests and for the purposes set out below.

Purpose of Use	Categories of Personal Data/used/processed for each purpose	Basis for Use/Processing
Fund interest administration, management of subscription, transfer of interests, completion of investments by our funds, maintaining the register of partners and distributions, maintaining accounts, managing distributions including the allocations of profit and loss between Investors, internal audit validations, communications, events, investor relations and more generally performance of services requested by and operations in accordance with the instructions of the Investor.	Where you are acting on behalf of an Investor: Contact and/or personal data such as first name, last name, telephone number, email address, residential address, business address, dietary preferences; and Government issued identifiers such as passport number, tax ID number.	Where you are acting on behalf of an Investor (including direct or indirect directors, officers, owners, beneficial owners, employees or advisors of an Investor): it is necessary for our legitimate interests (to ensure effective administration of the investment).
	Where you are an Investor who is an individual: Contact and/or personal data such as first name, last name, telephone number, email address, residential address, business address, dietary preferences; Government issued identifiers such as passport number, tax ID number; Information in relation to your net worth, history of investments, investment preferences and / or tax position, allocation of interests in any Partnerships in which you are an investor and/or allocation of profit or other distributions from such Partnerships; and Wire instructions.	Where the Investor is an individual: it is necessary for entry into and performance of a contract.
AML/KYC checks, screening against sanctions lists, background checks on whether the Investor or a connected person is a Politically Exposed Person and related actions of you, your employees, partners or third parties and compliance with all relevant legal, regulatory and administrative obligations and responsibilities of the Partnership and/or any member of the Hellman & Friedman Group and/or any counterparty of the Partnership (including providers of debt or equity finance and vendors)  including pursuant to any applicable Law, such as the Foreign Account Tax Compliance Act (“FACTA”), Common Reporting Standard (“CRS”) or similar reporting practices,  transactions reporting, complying with requests from, and requirements of, local or foreign regulatory or law enforcement authorities, tax identification and reporting, any other automatic exchange of information regimes.	Where you are acting on behalf of an Investor or where you are an Investor who is an individual: Contact information such as first name, last name, telephone number, email address, residential address, business address; Date of birth, place of birth, citizenship, tax residency, utility bills or other identification records; Government issued identifiers such as passport number; driver’s license number, tax ID number or other identifiers;	Necessary for compliance with legal and regulatory obligations including sanctions Laws/AML and KYC Laws and or any other Laws applicable to the data controller or other members of the Hellman & Friedman Group.
Risk management and fraud prevention purposes including in relation to completing certain transactions or account changes that you request or for the evaluation of the Investor’s financial needs, monitoring the Investor’s financial situation including for assessing its creditworthiness and solvency, to manage litigation, respond to court orders and legal or tax investigations, for our accounting purposes and for in-person meetings or events, or other health and safety purposes.	Where you are acting on behalf of an Investor or where you are an Investor who is an individual: Contact information such as first name, last name, telephone number, email address, residential address, business address; Government issued identifiers such as passport number, tax ID number; and KYC and/or AML documentation including proof of identity and proof of address (for example, utility bills, bank statements, driving licence, passport or other photo ID; health and safety information (such as vaccination details).	Necessary for our legitimate interests (to run an efficient and successful fund).
Monitoring and recording calls, messages and other communications for quality, business, regulatory analysis, and legal and regulatory compliance (including compliance with requirements applicable to other members of the Hellman & Friedman Group).	Communications, including mail, email, text messages (including through SMS, WhatsApp and similar channels), calls, voicemail and any other messages communicated to us, as well as contact information such as first name, last name, username, telephone number, email address, and time and content of communications.	Necessary for our legitimate interests (to run an efficient and successful fund and to meet regulatory compliance requirements). Necessary for compliance with legal and regulatory obligations.
For the purpose of receiving marketing materials and information about fundraising activities for new H&F Funds and investment entities. You can opt-out of receiving such communications at any time by contacting us at [email protected].	Where you are acting on behalf of an Investor or where you are an Investor who is an individual: Contact information such as first name, last name, telephone number, email address, time and content of call.	Consent, where required, or legitimate interests.
For the purpose of processing payments including in respect of transactions that you request	In relation to the Investor or those who may be acting on the Investors behalf: Contact information such as first name, last name, telephone number, email address. In relation to an individual Investor only: Wire instructions or other bank details, payment amounts and percentage fund ownership.	Where the Investor is an individual: it is necessary for entry into and performance of a contract. Where you are acting on behalf of an Investor: it is necessary for our legitimate interests (to ensure effective administration of the investment).

 

5. FOR HOW LONG DO WE RETAIN PERSONAL DATA?

We retain personal data for so long as necessary for us to fulfil our business purposes, in accordance with Firm policies and procedures, , including for effective management of firm practices (“Policies”). 

We may retain Personal Information for a longer period than as stated in our Policies:

1. Where required by law, regulation, legal or judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority with relevant powers, by the rules of applicable stock exchange or recognized marketplace, or by a regulator, bank examiner or self-regulatory organization or pursuant to mandatory ethics rules applicable to the Firm or its affiliates (collectively, “Law”) or
2. As reasonably required in relation to any claim or investigation pursuant to any Law and/or any matter which may lead to such a claim or investigation.

6. TO WHICH THIRD PARTIES WILL PERSONAL DATA BE DISCLOSED?

We disclose your personal data with selected third parties. The categories of recipients may include the following, as permitted by Law: 

• 6.1 Competent authorities (e.g., tax authorities, courts, ombudsmen, arbitral tribunals, governmental authorities, any stock exchanges or recognized marketplace, regulators, bank examiners or self-regulatory organizations (“Authorities”) and where needed for health and safety purposes, the applicable Authority);
• 6.2 Any member of the Hellman & Friedman Group, whether located in the UK, United States, Cayman Islands or elsewhere for the purposes of compliance with Law;
• 6.3 The relevant General Partner within the Hellman & Friedman Group for the purposes of reviewing new Investors (including conducting KYC / AML checks and screening against sanctions lists), fund administration, investor relations, compliance and legal functions and facilitating fundraising activities for new H&F Funds and investment entities;
• 6.4 Third party service providers located globally, providing investor portal services, investor data site services, conference management systems, legal services, accounting and administration services;
• 6.5 Third party service providers located globally, for the purpose of fund administration and investor relations;
• 6.6 Third party service providers located globally providing services (i) to enable us to fulfil our obligations pursuant to Law, for example, as required by the U.S. Securities and Exchange Commission, European Commission, Financial Conduct Authority, Cayman Islands Monetary Authority, and or applicable tax authorities and (ii) in relation to KYC (including credit/insolvency checks), AML, FACTA, CRS, applicable taxing authorities or other similar regimes or authorities and to advisors for legal and/or tax advice;
• 6.7 All partners in the relevant Partnership, who may be located globally and to whom we are required to provide a list of limited partners and advisory board members (or their designees);
• 6.8 Providers or potential providers of debt and/or equity finance, brokerage services, transfer agency services, custodial services or other financial services (“Financial Services”) to any Partnerships, limited partners, holding companies and / or any Portfolio Companies (in each case, in which the Investor is directly or indirectly invested), located in the jurisdiction in which such provider or potential provider of Financial Services is based, in order to enable such providers or potential providers of Financial Services to perform KYC, AML, FATCA, CRS and other checks for the purpose of providing Financial Services;
• 6.9 Transaction counterparties of any Partnerships, holding companies and / or any Portfolio Companies (in each case, in which the Investor is directly or indirectly invested), located in the jurisdiction in which such counterparty is located, in order to enable such counterparties to perform KYC, AML and other checks for the purpose of any relevant transactions;and
• 6.10 Other third party service providers located in the United States, the United Kingdom or other jurisdictions for e-mail archiving and searching, data storage and cloud computing.
• 6.11 Where any member of the Hellman & Friedman Group is under an obligation to do so pursuant to Law or where it determines that to do so is in its and/or its Investors’ best interests, it will disclose your personal data to regulators, courts, the police, tax authorities or other Authorities, or in the course of litigation or other proceedings or investigations, actual or threatened to opposing parties, arbitrators and/or tribunals. In some cases, it may not be reasonably practicable or possible in accordance with applicable Law, to notify you in advance about the details of such disclosures.
• 6.12 We will also disclose your personal data as necessary to respond to your requests and questions.
• 6.13 We do not, and will not, sell or share personal information, as those terms are used in the CCPA, including on individuals under age 16.

7. SAFEGAURDING PERSONAL DATA; INTERNATIONAL DATA TRANSFERS

Please contact [email protected] should you wish to examine these standard data protection clauses.

8. YOUR RIGHTS

8.1 Under the General Data Protection Regulation and similar international Laws, depending on your location:

• Right to Access: You may have the right to ask us to access your personal data and be provided with certain information about how we use your personal data and who we disclose it to.
• Right to Correct: You may have the right to ask us to correct your personal data where it is inaccurate or incomplete.
• Right to Delete:In certain circumstances, you may have the right to ask us to delete your personal data:
  • where you believe that it is no longer necessary for us to hold your personal data;
  • where you have withdrawn your consent to particular processing and there is no other legal ground available;
  • on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or
  • where you believe your personal data we hold is being unlawfully processed by us.
• Right to Restrict Certain Processing: In certain circumstances, you may have the right to ask us to restrict (stop any active) processing of your personal data:
  • where you believe your 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 the data 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.
• Right to Object: You can object to our processing of your personal data based on our legitimate interests and we may no longer process your personal information unless we can demonstrate an overriding legitimate ground.
• Right to Portability: In certain circumstances, you may have the right to ask us for a copy of your personal data in a structured, machine-readable format and to ask us to share (port) this data to another data controller.
• Right regarding Automated Processing: While you may contest a decision made about you based purely on automated processing, we do not currently use automated decision making with respect to you. Accordingly, this right is inapplicable.
• Right to Withdraw Consent: Where you have provided your consent to us processing your personal data, you may withdraw your consent, but this does not affect personal data processed prior to your withdrawal.

How to Exercise these Rights: To exercise any of these rights above, please email us at [email protected], with is without prejudice to your right to raise a concern with the applicable data protection supervisory authority.

8.2 Under the CCPA, if you are a California resident:

• Request to Know:You have the right to request that we disclose personal information that we have collected, sold or shared about you. Subject to verification and any limitations under the CCPA, we will disclose the following:
  • The categories of personal information we have collected;
  • The categories of sources from which the personal information was collected;
  • The business or commercial purpose for which we collected the personal information;
  • The categories of third parties with whom we disclose personal information; and
  • Specific pieces of personal information that we have collected about you.
• Right to Delete: You have the right to delete personal information that we collected from you, subject to exceptions.
• Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you.
• Right to Limit Use of Sensitive Personal Information: You have the right to request that we limit the use and disclosure of your sensitive personal information. We do not use or disclose your sensitive personal information other than as permitted for purposes specified in section 7027, subsection (l) of the CCPA.Accordingly, this right is inapplicable.
• Right to opt-out of sale/sharing: You have the right to opt out of the sale/sharing of your personal information. We do not sell or share your personal information with third parties as those terms are used in section 7013, subsection (g) of the CCPA.  Accordingly, this right is inapplicable.
• If you are a California resident, you have the right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA .
• How to Exercise these Rights: To exercise any of the above rights, you may submit a request by:
  • Calling us toll-free at +1 (877) 215-0023;
  • Visiting https: https://hf.com/your-california-consumer-privacy-act-rights/; or
  • Emailing us at [email protected].
• We will verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA. The request must provide sufficient information that allows us to reasonably verify that you are the individual about whom we hold the Personal Information.
• Only you or someone legally authorized to act on your behalf, may make a verifiable request under the CCPA.Any such authorization must be in accordance with California Civil Code section 1633.1 et seq., the Uniform Electronic Transactions Act. To act on such request, your authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on your behalf.

9. CHANGES TO THIS NOTICE

9.1  This Privacy Notice is effective October 11, 2024.  The Notice may be amended from time to time.  Any updated Notie will be available on hf.com.