Privacy Policy
Last updated November 2024
OUR COMMITMENT TO PRIVACY
The privacy of your personal data - such as your name, contact details or any other information from which you can be identified, either directly or indirectly – is of the utmost importance to Integrum Holdings LP and its affiliates (together, “Integrum,” “our,” “us,” or “we”). To better protect your privacy, we are providing information explaining our online information practices.
This Website Privacy Policy (this “Policy”) describes how we gather and use information for visitors of this website, including but not limited to any non-public personal information (as defined under the Gramm-Leach-Bliley Act). Please read this Policy carefully. This Policy is intended to provide information to individuals from whom we obtain personal data directly, as well as to those from whom we may acquire personal data indirectly (for example, if you provide us with another person’s contact details). This Policy may be updated from time to time and any such updates will be posted here. We encourage you to review the Policy each time you visit this website.
This Policy is not directed towards our employees, officers, or directors, or to investors, or prospective investors in us or in funds that we sponsor or manage. We address these relationships in separate policies relating to human resources and investor communications.
This Policy constitutes a legally binding agreement between Integrum and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Policy, please do not access, or use this website.
This Policy also does not apply to any other third-party website, including those that may be linked to in our website. We do not control the privacy policies or practices of others. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.
As used in this Policy, “personal information” and “personal data” shall have the meanings given to such terms in the CCPA and GDPR, respectively.
Visitors that are residents of California should refer to our California Website Privacy Policy supplement below.
Visitors that are residents of the European Union, the European Economic Area, or the United Kingdom, should refer to our GDPR Privacy Notice below.
THE INFORMATION WE COLLECT
We may collect the following types of personal information from users of this website:
- Identifiers, such as real name, phone number, personal identifier (such as device identifier; cookies, beacons and similar technology), online identifier, internet protocol address, e-mail address, and other similar identifiers; and
- Internet or other electronic network activity information, such as information regarding your use of our website (e.g., browser type and version, cookies, browsing history and/or search history, and information regarding your interaction with our website and applications), as well as information you provide to us when you correspond with us in relation to inquiries.
We may collect personal information from third-party sources, which may include publicly available sources of information. Additionally, we may collect and retain a record of all communications with you, in accordance with applicable regulatory statutes.
HOW INFORMATION IS USED
We may use your personal information for one or more of the following business purposes:
- To improve and maintain our website;
- To communicate with you, including responding to requests for information submitted by you through our website;
- To debug, to identify and to repair errors that impair existing intended functionality, such as on our website;
- To undertake internal research for technological development and demonstration;
- To ensure security and integrity, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity; and
- To generally comply with U.S., state, local and non-U.S. laws, rules, and regulations.
To the extent that you provide us with any personal information through or in connection with this website, we may use such information for Integrum’s business purposes but will not disclose any personal information about you to anyone, except as permitted or required by law or regulation and to governmental agencies or pursuant to legal process. In providing personal information to Integrum, you consent to Integrum’s use of such personal information for the purposes described in this Policy. We may also disclose your personal information to applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets, or shares.
CAPACITY
You represent to Integrum that you have the authority to visit this website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
COOKIES
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently, as well as to provide information to the owner of the website. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
When you visit our website, we may place a “cookie” or other online tracking device (e.g., Web beacons) in order to improve your experience by recognizing you when you visit the website, such as by assigning a session ID and delivering content specific to your interests. The cookies we place may also collect information about your IP address or click stream data within our website (i.e., the actions taken in connection with the website). This information helps us improve the functionality of the website.
Web browsers often allow you to erase existing cookies from your hard drive, block the use of cookies, and/or be notified when cookies are encountered. If you elect to block cookies, please note that you may not be able to take full advantage of the features and functions of the website.
We do not control any cookies, web beacons, or other similar devices that may be placed on our website by third parties.
CONSENT
Except where cookies are necessary for the operation of our website, we will obtain your consent before setting cookies. You can give or withdraw your consent to our use of these cookies at any time by using the cookie banner preference center on our website.
DO NOT TRACK
We do not track visitors of our website over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third-party sites do keep track of your browsing activities through the use of cookies when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties, particularly advertisers, know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.
SECURITY AND RETENTION OF PERSONAL INFORMATION
We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know that information to provide our services to you. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
However, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through our website and will not be responsible or liable for any damages, losses, or causes of action arising out of or in connection with the disclosure of personal information; any transmission of information or data by you to or through this website is at your sole risk.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Policy unless a longer retention period is required by law, for compliance with our legal obligations, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact the Chief Compliance Officer of Integrum at contact@integrum.us.
NOTIFICATION OF CHANGES
We reserve the right to amend this Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Policy. Accordingly, users are strongly encouraged to review our Policy regularly. If we decide to change our Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of the Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Policy, please stop accessing this website. Please check this page frequently and review any changes to this Policy carefully so you are aware of any changes, as they are binding on you.
MISCELLANEOUS
The provisions in our Terms of Use are hereby incorporated by reference.
CONTACT US
If you have any questions or concerns about this Policy, please contact:
- Call us toll-free at (212) 970-2500;
- Email us at the following email address: contact@integrum.us outlining your request and be sure to include your contact information; or
- Submit your request, along with your contact information, via our contact form at: https://www.integrum.us/contact
GOVERNING LAW
The laws of the State of New York govern this Policy and your use of this Site in all respects. Any dispute relating to this Policy and your use of this Site shall be resolved solely in the state or federal courts located in New York, New York. You consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute, controversy or claim and agree to waive trial by jury in any such dispute.
CALIFORNIA WEBSITE PRIVACY POLICY
This California Website Privacy Policy (the “California Website Privacy Policy”) supplements the Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, 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 Policy.
What does this Website Privacy Policy apply to?
This California Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to us through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.
What information do we collect about you?
We may collect (and may have collected during the 12-month period prior to the last updated date of this privacy notice) the following categories of personal information about you through our website, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us:
- Identifiers, such as name, contact details and address (including email address and IP address);
- Other customer records, such as telephone number and personal information provided in connection with via the “Contact” page;
- Internet or other electronic network activity information, such as information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries
For additional details about the personal information we may collect, please refer to the section titled “What Information We Collect” above.
We do not knowingly collect or solicit personal information from anyone under the age of 18.
We do not collect or process any sensitive personal information from you other than for purposes specified in Section 7027(m) of the CCPA Regulations.
To the extent we process deidentified information, we will solely use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Directly from you, such as when you contact or communicate with us in connection with this Website (including through email), including any update notices provided by you; and
- From your use of our Website, including registration information, information provided through online forms and any information captured via cookies.
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
How long do we retain your personal information?
For each of the categories of personal information that we collect (listed above), we retain such personal information only for as long as reasonably necessary to fulfill the purposes we collected it for, including for purposes of satisfying any legal, regulatory, accounting or reporting requirements, unless a longer retention period is otherwise required by law, for compliance with our legal obligations, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
How do we use your personal information?
We will use your personal information for one or more of the business purposes described in the section titled “How Information is Used” above.
Who do we disclose your personal information to?
We do not “sell” or “share” (as such terms are defined by the CCPA) any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to advisory committee members, senior advisors, other professional advisors, recruitment firms, consultants, placement agents, data hosting providers, administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants, and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Within the last twelve (12) months, we may have disclosed each of the categories of personal information collected in connection with this Website with affiliates and service providers and as described in the section titled “How Information is Used” above.
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 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.
Correction Rights: You have the right to request that we correct inaccurate personal information about you.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. 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 to whom we disclose the personal information
- the specific pieces of personal information we have collected about you
- whether we disclosed your personal information to a third-party, and, if so, the categories of personal information that each recipient obtained
Non-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 using any of the methods set forth below.
- Call us toll-free at (212) 970-2500;
- Email us at the following email address: contact@integrum.us outlining your request and be sure to include your contact information; or
- Submit your request, along with your contact information, via our contact form at: https://www.integrum.us/contact
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 (such as your name, e-mail address, mailing address, phone number, company name, job details or investor portal access credentials, if applicable) to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, if 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.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required (up to 90 days). If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Please contact contact@integrum.us with any questions about this California Website Privacy Policy.
CALIFORNIA’S SHINE THE LIGHT LAW
California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our website users who are California residents to request and obtain from us a list of their personal information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not disclose any personal information to third parties for their direct marketing purposes.
EUROPEAN ECONOMIC AREA AND UNITED KINGDOM
This section of the Policy applies to the extent that the EU General Data Protection Regulation (Regulation 2016/679) (the “EU GDPR”) or the “UK GDPR” (as such term is defined in the UK Data Protection Act 2018, and together with the EU GDPR, the “GDPR”) applies to our processing of your personal data.
As used in this section:
- “controller” means the entity that decides how and why personal data is processed;
- “personal data” means information from which it is possible to identify a natural person (an individual), or information from which any individual is identifiable;
- “personal data breach” means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed;
- “processing” means anything that is done with personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (and “process” and “processed” shall be construed accordingly);
For the purposes of the GDPR, Integrum and its affiliated general partners and managing members will each be a controller of your personal data. If you have any questions regarding our use of your personal data, or this Policy, please contact the Chief Compliance Officer of Integrum at contact@integrum.us.
Personal data which you may provide to us and which we may collect includes identifiers, such as name, title, telephone number and other contact information, email, IP address, and internet or other electronic network activity information (such as information regarding your use of our website (e.g. cookies, browser type/version, browsing history and/or search history) as well as information you provide to us when you correspond with us).
We rely on various legal bases under applicable data protection legislation to process your personal data, including where the processing is necessary for our legitimate interests (or those of a third-party), performance of a contract or in order to take steps at your request prior to entering into a contract, or compliance with a legal obligation to which we are subject. We may use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal data about you – this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offenses.
If we require your personal data due to a legal requirement, obligation, or to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data.
Failure to provide personal data may mean that you are not able to use our website, we cannot provide our services or products to you, we may not be able to interact with you and/or we may need to terminate our business relationship with you.
Further information about the legal bases under which we process your personal data is included in the section headed “Why We Use Your Personal Data” below.
Further information about the potential categories of recipients of your personal data and transfers of personal data outside of the EEA/UK is included in “Disclosure and Transfer of Personal Data” below.
You do not need to take any action as a result of this Policy, but you do have certain rights as described below in the section headed “Your Rights.”
HOW WE OBTAIN YOUR PERSONAL DATA
Information You Provide to Us
We may collect your personal data when you decide to interact with us, and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal data via email, post, telephone, and this website.
Information Provided through Technology
We collect personal data about you through technology. For example, we collect your IP address each time you request a page during a visit to the website. At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the website.
Information Provided by Third Parties
We also obtain personal data about you from third parties acting on our behalf, such as our website host, including the frequency with which you visit our website and the links you use. Where we are evaluating a company in connection with a potential investment in or purchase of such companies, we may obtain personal data about you from the company in question.
WHY WE USE YOUR PERSONAL DATA
To the extent that you provide us with any personal data, through or in connection with this website (i.e., via telephone, email, or post), we may use such personal data for the following if necessary:
For compliance with legal obligations
- To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.
- To keep a record of your relationship with us
To pursue our legitimate interests or those of a third party, except where such interests are overridden by your interests, fundamental rights or freedoms
- To conduct due diligence activities with an actual or prospective corporate transaction or investment with respect to which we are party to.
- To keep a record of your relationship with us.
- Litigation management and conducting internal audits and investigations.
- To administer and protect our business and this website.
No automated decision-making, including profiling, is used when processing your personal data.
DISCLOSURE AND TRANSFER OF PERSONAL DATA
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
Your personal data may be disclosed to and processed by our affiliates and certain service providers as necessary to fulfill the purposes set out in this Policy, including advisory committee members, senior advisors, other professional advisors, recruitment firms, consultants, placement agents, data hosting providers, administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, and self-regulatory organizations. We may also transfer personal data with business partners or potential business partners in the event of a merger or sale, or in the event of a transfer of our assets or operations. We seek to ensure that anyone who provides a service to, or for us, involving personal data enters into an agreement with us and meets our standards for data security.
If you are in the EEA or the UK and transfer your personal data to us directly, you will be transferring such data voluntarily and entirely at your discretion to our offices in the United States. The United States does not have data protection and privacy laws that provide the same degree of protection as those in the EEA or the UK.
If we were to process your personal data in the context of an establishment in the EEA or the UK and transfer your personal data to a recipient outside of the EEA and/or the UK, or if we are otherwise subject to restrictions on the transfer of your personal data under equivalent laws of a country outside the EEA/UK (as applicable), we will only do so pursuant to a valid transfer mechanism such as:
- an adequacy decision by the European Commission/ UK government (or equivalent);
- data transfer agreements and/or safeguards using terms approved by the European Commission/ UK’s Information Commissioner’s Office (or equivalent); and/or
- other valid transfer mechanisms.
For further information about the safeguards/derogations used, please contact the Chief Compliance Officer of Integrum at contact@integrum.us.
We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us (subject to applicable law). Should we, or any of our affiliated entities, be the subject of a takeover, divestment, or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL DATA
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a personal data breach where we are legally required to do so.
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Policy unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. For further information about how long we will keep your personal data, please contact the Chief Compliance Officer of Integrum at contact@integrum.us.
CAPACITY
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that personal data.
YOUR RIGHTS
You have the rights listed below in relation to your personal data (subject to applicable law). To exercise these rights, please contact the Chief Compliance Officer of Integrum at contact@integrum.us.
- Access: You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the personal data you have requested.
- Correction: You may request that we correct your personal data if it is inaccurate or not complete.
- Deletion: You may request that we delete your personal data in certain circumstances.
- Restrictions on use: You may request that we stop processing your personal data(other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) the processing is against the law and you oppose the erasure of the personal data and request the restriction of their use instead; (iii) we no longer need your data for the purposes for which it was collected, but you still need your data to establish, exercise or defend a legal claim; or (iv) you have objected to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing (to the extent applicable) or (ii) where processing is based on legitimate interests, although, in some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which may override your right to object.
- Portability: If you wish to transfer your personal data to another organization – and certain conditions are satisfied – you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: We do not generally rely on your consent to process personal data. However, to the extent we do rely on your consent – provided by a clear affirmative action – to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data, or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
NOTIFICATION OF CHANGES
We reserve the right to amend and update this Policy from time to time. If we decide to change our Policy, we will post those changes so our users are always aware of what personal data we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect additional personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users.
CONTACT US
If you have any questions or concerns about this Policy, or you believe you may be entitled to rights provided under the GDPR and want to exercise such rights, please contact the Chief Compliance Officer of Integrum at contact@integrum.us.
COMPLAINTS
Should you wish to make a complaint about how we process your personal data, please contact the Chief Compliance Officer of Integrum at contact@integrum.us and we will work to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with your local data protection supervisory authority. A list of the EEA data protection authorities is available via: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. In the UK, the relevant body is the Information Commissioner’s Office, please see https://ico.org.uk/make-a-complaint.
Last updated November 2024