PRIVACY POLICY

HELLMAN & FRIEDMAN LLC ONLINE PRIVACY POLICY

1. PURPOSE

1.1 This online privacy policy (the “Online Privacy Policy”) describes the types of personal information Hellman & Friedman LLC, and/or its affiliated private equity 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 we hold about you.  This Online Privacy Policy, including the rights referred to in Section 8 below, shall apply only to individuals who visit the Website (and not to entities, to the extent those individuals represent those entities).

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

E-mail: privacy@hf.com 
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 European General Data Protection Regulation (the “GDPR”) and may be contacted at the below with respect to matters relating to its responsibilities as the data controller:

E-mail: privacy@hf.com  
Phone: +44 (0)20 7839 5111
Post: 30th Floor Millbank Tower, 21-24 Millbank, London SW1P 4QP

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 (the “Investor Privacy Notice”). Your use of this Website is also subject to the Terms of Use available on the Website.

2. PERSONAL INFORMATION WE RECEIVE 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 we will receive other information regarding your use of the Website.  We collect, and have collected over the last twelve (12) months, the following personal information about visitors to the Website:

(a) Information you may choose to submit to H&F using any means of contact listed on the Website, such as an email address or phone number. In such instances, we will use such information to maintain our business records, manage our relationship with you, communicate with you, and  comply with Law (defined below) and will not disclose such information to any outside party, other than as set out below;

(b) If you are a Hellman & Friedman Investor and you choose to access the Investor Portal, we will also collect your email address to provide you with log in credentials and to allow you to access the Investor Portal;

(c) Your IP address, for the purpose of monitoring access to the Website;

(d) Cookies (as described in Section 5 below), 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; and

(e) Information you submit when you make requests pursuant to Section 8, will be used for the purposes of responding to those requests or as otherwise permitted by law.

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

3. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION

3.1 To the extent we collect personal information about you via the methods described in Section 2.1, we do not share such personal information with any parties outside of our company other than as set out below.

3.2 We share, and have shared over the last 12 months, personal information collected about you via our Website with selected third parties. The categories of recipients include the following (which may be updated from time to time): 

(a)  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”);

(b)  Web hosting service providers, including WP Engine and 4-mil3;

(c)  Email and other IT service providers, including Global Relay and Microsoft;

(d)  Investor Portal service providers, including Investran DX (FIS Global). For more information on how we use personal information we collect from users on the Investor Portal within the European Union, please refer to the Investor Privacy Notice;

(e)  Providers of professional advisory services, including consultants, legal advisors and accountants and other third party service providers; and

(f)   members of the Hellman & Friedman Group.

3.3 We do not, and will not, sell personal information collected about you.

4.  HOW WE PROTECT PERSONAL INFORMATION COLLECTED ABOUT YOU

4.1 We maintain operational policies, including physical, electronic and procedural protections, designed to safeguard and secure our data networks against unauthorized 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.

5.  COOKIES

5.1 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.

5.2 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.

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

5.4 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/.

5.5 “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. 

6.  RIGHTS UNDER THE GDPR

6.1 Where the GDPR applies, you may have the following rights in relation to personal information that constitutes “personal data” as defined in the GDPR:

(a)  You have the right to ask us to correct your personal information where it is inaccurate or incomplete.

(b)  You have the right to ask us to access the personal information we hold about you and be provided with certain information about how we use your personal information and who we share it with.

(c)  In certain circumstances, you have the right to ask us to delete the personal information we hold about you:

(i)   where you believe that it is no longer necessary for us to hold your personal information;

(ii) where we are processing your personal information on the basis of legitimate interests and you object to such processing and we cannot demonstrate an overriding legitimate ground for the processing; or

(iii) where you believe the personal information we hold about you is being unlawfully processed by us.

(d)  In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal information:

(i)   where you believe the personal information we hold about you is inaccurate and while we verify accuracy;

(ii) where we want to erase your personal information as the processing is unlawful but you want us to continue to store it;

(iii)  where we no longer need your personal information for the purposes of our processing but you require us to retain the data for the establishment, exercise or defence of legal claims; or

(iv) where you have objected to us processing your personal information based on our legitimate interests and we are considering your objection.

(e)  In addition, you can object to our processing of your personal information based on our legitimate interests and we will no longer process your personal information unless we can demonstrate an overriding legitimate ground.

6.2 To exercise any of these rights above, please email us at privacy@hf.com.

6.3 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.

6.4 In the event that you wish to make a complaint about how we process personal information about you, please contact us in the first instance at privacy@hf.com and we will endeavour to deal with 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 EU country in which you live or work or where you think we have infringed data protection laws.

7.  TRANSFERS OF PERSONAL INFORMATION UNDER THE GDPR

7.1 The personal information we collect about you via our Website will be transferred to, and stored at, destinations outside the European Economic Area (the “EEA”) including, without limitation, in the United States. It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers set out below. Personal information 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 information to third countries, pursuant to Decision 2004/915/EC or by way of the European Commission’s standard contractual clauses for the transfer of personal information to third countries, pursuant to Decision 2010/87/EU (together, the “Model Clauses”) and (ii) to legal and other professional advisers of members of the Hellman & Friedman Group. A copy of the Model Clauses may be obtained on your request to privacy@hf.com.  

7.2 “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.

8.  CALIFORNIA RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT

8.1 Where applicable, California residents have the following privacy rights under the California Consumer Privacy Act of 2018 (the “CCPA”) in relation to their “personal information” as defined in the CCPA:

(a)  Right to Access: You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you. Subject to verification and to the extent required by the CCPA, we will disclose to you:

(i)   the categories of personal information we have collected about you;

(ii) the categories of sources from which the personal information is collected;

(iii)  the purpose for collecting your personal information;

(iv) the categories of third parties with whom we have shared that personal information; and

(v) the specific pieces of personal information we have collected about you.

(b)  Right to Delete: Subject to any applicable exception, you have the right to request that we delete any personal information that we collected from you and retained.  Unless an exception applies, subject to verification and to the extent required by the CCPA, we will delete personal information collected about you from our records.

(c)  Freedom from Discrimination: You have the right, to the extent required by the CCPA, to be free from unlawful discrimination for exercising any of the rights above.  

8.2 To request your exercise of the rights described above, please submit a request to us by either:

(a)  Calling us toll-free at +1 (877) 215-0023;

(b)  Visiting Know Your California Rights; or

(c)  Emailing us at privacy@hf.com.

8.3 We will need to verify your identity prior to addressing or fulfilling a request made pursuant to the CCPA.  Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information.

8.4 Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to personal information collected about you.  To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf. 

9.  THIRD PARTY WEBSITES

9.1 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.

10.  CHANGES TO THIS ONLINE PRIVACY POLICY

10.1  This Online Privacy Policy was last updated on January 1, 2020. 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.