California Website Privacy Policy

Last Updated: 3rd May 2023

This Trident Capital California Website Privacy Policy supplements the Trident Capital U.S. Website Privacy Policy to which this is addended with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Trident Capital U.S. Website Privacy Policy (See link above). To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this Website Privacy Policy apply to?

This California Website Privacy Policy applies solely to your interactions with us through this website. If you provide personal information to use through another means (e.g., as an investor or an employee seeking employment) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We do not collect nonpublic personal information through this website other than information you may for your own purposes elect to share with us. We use strictly essential functional cookies only on this website, which collect anonymized data only solely to help us maintain website functionality. We do not knowingly collect or solicit personal information from anyone under the age of 18.

We do not collect or use sensitive personal information through this website.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

How do we obtain your personal information?

How do we use personal information?

We do not collect nonpublic personal information through this website other than information you may for your own purposes elect to share with us. We use strictly essential functional cookies only on this website, which collect anonymized data only solely to help us maintain website functionality. If you do elect for your own purposes to share personal information with us, we may use such personal information for one or more of the following business or commercial purposes:

To perform services for you, including but not limited to the administrative processes (and related communication) in connection with an investment.
To create, maintain, customize, and secure your account with us.
To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
To provide advertising and marketing services.
To keep a record of your relationship with us.
To conduct ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
To keep investors informed about the business of the general partner or managing member of the applicable investment vehicle and its affiliates generally, including investor notices and reporting.
To audit and verify the quality and effectiveness of our services and compliance.
To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
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. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in marketing emails.

We retain the categories of personal information set forth above in “What Information Do We Collect About You?” section of this California Website Policy only as long as is reasonably necessary for those purposes set forth above in “How Do We Use Your Personal Information?”, except as may be required under applicable law, court order or government regulations.

To whom do we disclose your personal information?

We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

How do we keep your personal information secure?

We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

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 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.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. 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 with 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.

Correction Right: You have the right to request that we correct any inaccuracies in the 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.

No 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, a different level or quality of service to you.

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.

Contact Us

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 by calling us toll free at the phone number in the footnote below[1].

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 (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. We may also verify your request through contact information you have previously provided to us, and may do so ourselves or through our fund services provider. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that 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.

If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact Howard S. Zeprun, General Counsel and Chief Compliance Officer of Trident Capital Management, LLC, at the email address in the footnote below[2], with any questions about this California Website Privacy Policy.

[1] eight-five-nine-seven-three-one-five in country code one and local code eight-eight-eight

[2] hzeprun@tridentcap.com