PRIVACY POLICY

HELLMAN & FRIEDMAN LLC
ONLINE PRIVACY POLICY

  1. PURPOSE

1.1 This privacy policy (the “Online Privacy Policy”) describes the types of personal information (also called personal data) that Hellman & Friedman LLC, and/or its affiliated entities (“H&F”, “we”, “our”, “us”) receives about you when you visit www.hf.com (the “Website”) and what we do with it, how we protect it, and how you can contact us if you have a question or concern about the personal information collected through this Website.  

1.2 The Firm may be contacted at the below for all questions relating to this Online Privacy Policy:

          E-mail: [email protected]
          Phone: +1 (415) 788-5111
          Post: 415 Mission Street, Suite 5700, San Francisco, CA 94105

1.3 The Firm is the data controller for the purposes of the Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations and the Data Protection Act of 2018 and the European General Data Protection Regulation (collectively, the “GDPR”, each as may be amended from time to time), and may be contacted at the below with respect to matters relating to its responsibilities as the data controller:

         E-mail: [email protected]
         Phone: +44 (0)20 7839 5111
         Post: The Brunel Building, 2 Canalside Walk, London W2 1DG

1.4 If you are an investor or potential investor in a Hellman & Friedman fund entity, or affiliated co-investment entity, or a representative thereof (together, “Hellman & Friedman Investors”), you may also have access to the dedicated investor area of the Website (the “Investor Portal”). This Online Privacy Policy is in addition to our Hellman & Friedman LLC Investor Privacy Notice, which is available on the Investor Portal and applicable to Hellman & Friedman Investors.

1.5 If you are a candidate for employment or internship with H&F, this Online Privacy Policy is in addition to our Candidate Privacy Notice.

1.6 If you are a H&F business contact, this Online Privacy Policy is in addition to our Business Contacts Privacy Notice.

  1. PERSONAL INFORMATION WE COLLECT WHEN YOU VISIT OUR WEBSITE AND HOW WE USE IT

2.1 When you visit the Website, you may provide us with certain information about yourself and separately, we will receive other information regarding your use of the Website automatically.

We collect the following personal information about visitors to the Website:

    1. Personal Information — Should you choose to submit it to H&F using any means of contact listed on the Website, such as your name, email address and phone number and information you submit when you make requests pursuant to Section 7 or 9, will be used for the purposes of responding to those requests, to maintain our business records, manage our relationship with you, communicate with you, or as otherwise permitted by Law (defined below); and
    2. Internet or Online Information —Your IP address, browsing history and information regarding interaction with our Website from cookies and similar technologies (as described in Section 6), for the purpose of enabling us to track usage so that we can improve the Website, for IT system security purposes and to help us in the ongoing maintenance of the Website.

2.2 We process such personal information about you based on our legitimate business interests as described in Section 2.1.

  1. TO WHOM DO WE DISCLOSE PERSONAL INFORMATION COLLECTED VIA THIS WEBSITE

3.1 We disclose personal information collected about you via our Website with selected third parties. The categories of recipients include the following:

    1. All recipients to whom we may be required to disclose such personal information when required by a valid subpoena or court order, or as otherwise required by applicable law, regulation, legal or judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority with relevant powers, or by the rules of applicable stock exchange or recognized market place, or requested or required by a regulator, bank examiner or self-regulatory organization or pursuant to mandatory ethics rules (together, “Law”);
    2. Web hosting and e-mail service providers; other IT service providers;
    3. Investor Portal service providers. For more information on how we use personal information we collect from users on the Investor Portal, please refer to the Investor Privacy Notice;
    4. Providers of professional advisory services, including consultants, legal advisors and accountants and other third-party service providers; and
    5. Members of the Hellman & Friedman Group (defined below).

3.3 We do not, and will not, sell or share Personal Information, as those terms are used in the California Consumer Privacy Act of 2018 (the “CCPA”), including on individuals under age 16. 

  1. FOR HOW LONG DO WE RETAIN PERSONAL DATA COLLECTED VIA THE WEBSITE

4.1 We retain personal data for so long as necessary to fulfil our business purposes, in accordance with schedules contained in Firm policies and procedures (“Policies”). 

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

    1. Where required by 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.
  1. HOW WE PROTECT PERSONAL INFORMATION COLLECTED ONLINE

5.1 We maintain technical and organizational measures, designed to safeguard and secure our data networks against accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure or access to personal information we may collect through our Website and have implemented policies designed to ensure that personal information we collect via our Website is used in compliance with this Online Privacy Policy.

  1. COOKIES

6.1 Like many websites, our Website uses “cookies” to collect information about how the Website is used. A cookie is a small data text file which a website stores on your computer’s hard drive, if permitted by your web browser.

6.2 We use cookies to identify you as a unique user when visiting our Website, to enable us to track usage so that we can improve the Website, for IT system security purposes and to help us in the ongoing maintenance of our Website.

6.3 This technology does not provide us with any information about your name, address phone number or email address. We do, however, log visitor IP addresses.

6.4 Most browsers are initially set up to accept cookies. You can reset your browser to notify you when you have received a cookie, or alternatively, to refuse to accept cookies. However, you may not be able to use certain features on our website if you choose not to accept cookies. You can find more information about cookies and how to manage them at  http://www.allaboutcookies.org/.

6.5 “Do not track” signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. The Website does not respond to “do not track” signals in your web browser.

  1. RIGHTS UNDER THE GDPR

7.1 Where the GDPR (or similar international law) applies, you may have the following rights in relation to personal information that constitutes “personal data” as defined by Law:

a. Right to Access: You may have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we disclose it to.

b. Right to Correct: You may have the right to ask us to correct your personal data where it is inaccurate or incomplete.

c. Right to Delete:

    You may have the right to ask us to delete your personal data:

    1. where you believe that it is no longer necessary for us to hold your personal data;
    2. where we are processing your personal data on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; or
    3. where you believe your personal data is being unlawfully processed by us.

 

d. Right to Restrict Certain Processing:

     You may have the right to ask us to restrict (stop any active) processing of your personal data:

    1. where you believe the personal data we hold about you is inaccurate and while we verify accuracy;
    2. where we want to erase your personal data as the processing is unlawful, but you want us to continue to store it;
    3. 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
    4. where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection.

 

e. Right to Object:

You may have the right to object to our processing of your personal data based on our legitimate interests, and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

f. Right regarding Certain Automated Processing:

While you may contest a decision made about you based purely on automated processing, the Firm does not currently use automated decision making so this right is inapplicable.

g. Right to Withdraw Consent:

Where you have provided your consent to us for processing your personal data, you may have the right to withdraw your consent, but this does not affect personal data processed prior to your withdrawal.

7.2 How to Exercise these Rights:

To exercise any of these rights above, please email us at [email protected].

7.3 Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or the interests of any member of the Hellman & Friedman Group (including their proprietary information, trade secrets or intellectual property), or where there are overriding public interest reasons or where we are required by Law or bona fide internal policies and procedures to retain your personal information.

7.4 In the event that you wish to make a complaint about how we process personal data about you, please contact us in the first instance at [email protected] and we will endeavor to handle your request as soon as possible. This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the location in which you live or work or where you think we have infringed data protection laws.

  1. INTERNATIONAL DATA TRANSFERS

8.1 The personal data we collect about you via our Website will be transferred to, and stored at, destinations outside the UK and the European Economic Area (the “EEA”) including, without limitation, in the United States. It will also be processed by staff operating outside the UK or the EEA who work for us or for one of our vendors. Personal data  about you is transferred (i) within the Hellman & Friedman Group (as defined below) by way of the European Commission’s standard contractual clauses for the transfer of personal data to third countries (the “EU SCCs”) or Section 119A of the UK Data Protection Act 2018 and the associated addendum to the EU SCCs (the “UK Addendum”) or International Data Transfer Agreement (the “UK IDTA”), each as may be amended from time to time, as applicable and (ii) to legal and other professional advisers of members of the Hellman & Friedman Group by way of the EU SCCs and/or the UK Appendix or UK IDTA, or other mechanism deemed adequate under applicable law.  A copy of the EU SCCs and the UK Appendix or UK IDTA, as applicable, may be obtained on your request to [email protected].

8.2 “Hellman & Friedman Group” means H&F and any entity controlled by or under common control with H&F, excluding any portfolio companies in which funds affiliated with any members of the Hellman & Friedman Group are invested.

  1. RIGHTS UNDER THE CCPA

9.1 Request to Know: 

If you are a California resident, you have the right to request that we disclose personal information that we have collected, sold or shared about you, as those terms are used therein. Subject to verification and any limitations under the CCPA, we will disclose the following:

    1. The categories of personal information we have collected;
    2. The categories of sources from which the personal information was collected;
    3. The business or commercial purpose for which we collected the personal information;
    4. The categories of third parties with whom we disclose personal information; and
    5. Specific pieces of personal information that we have collected about you.

9.2 Right to Delete:

If you are a California resident, you have the right to delete personal information that we collected from you, subject to exceptions.  

9.3 Right to Correct:

If you are a California resident, you have the right to request that we correct inaccurate personal information that we maintain about you.

9.4 Right to Limit Use of Sensitive Personal Information:

If you are a California resident, you have the right to request that we limit the use and disclosure of your sensitive personal information, as defined in the CCPA.  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.

9.5 Right to opt-out of sale/sharing:

If you are a California resident, you have the right to opt out of the sale/sharing of your personal information.  We do not sell or share your personal information as those terms are used in section 7013, subsection (g) of the CCPA.  Accordingly, this right is inapplicable.

9.6 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, including, as applicable, an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of your CCPA rights. 

9.7 How to Exercise these Rights:

      To exercise any of the above rights, you may submit a request by:

    1. Calling us toll-free at +1 (877) 215-0023;
    2. Visiting https: https://hf.com/your-california-consumer-privacy-act-rights//; or
    3. Emailing us at [email protected].

9.8 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.  

9.9 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.  

  1. THIRD PARTY WEBSITES

10.1 Our Website contains links to websites controlled and maintained by our current or former portfolio companies and other third parties, such as social media networks. We provide these links solely as a convenience for you. These features are recognizable by their third-party brand or logo and may collect your IP address and set a cookie to enable the feature to work properly. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites is used.  This Online Privacy Policy does not govern the use of information collected on such third-party websites.

  1. CHANGES TO THIS ONLINE PRIVACY POLICY

11.1 This Online Privacy Policy was last updated on January 1, 2023. We reserve the right to modify, amend, add to, replace or remove this Online Privacy Policy at any time. Any changes we may make to this Online Privacy Policy in the future will be posted on the Website.