Angeles Equity Partners, LLC website privacy policy
Last Updated JULY 1, 2020
Thank you for visiting a website managed by Angeles Equity Partners, LLC (together with its affiliates, “Angeles Equity Partners” or “we” or “us”). This document sets forth Angeles Equity Partner’s website privacy policy (“Policy”). Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. By using this website, you agree to and accept the terms of the Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS POLICY, PLEASE DO NOT USE THE WEBSITE.
Applicability Of The Policy
This Policy applies to any personally identifiable information (“personal information” or “personal data”) that you provide to us or we collect about you through the website.
For purposes of this Policy, an affiliate is an entity that (i) controls the funds we directly or indirectly manage (the “Funds”), (ii) is controlled by the Funds, or (iii) is under common control with the Funds. Nonaffiliated third parties are parties who are not affiliates of the Funds.
This Policy applies specifically, but not exclusively, to the websites www.angelesequity.com, www.angelesequitypartners.com, and any other websites owned, operated or provided by Angeles Equity Partners (collectively, the “websites” or individually, the “website”).
Please note that our investors should read this Policy in conjunction with the Privacy Policy provided to investors separately. That policy specifically addresses how we treat investors’ nonpublic personal information and covers such information we may receive through various communication methods (not limited to the websites).
Persons Under 18 Years Of Age
We do not market to or enter into contracts with children nor do we intend to collect personal data from any person under 18 years of age. Please do not access or use any of the websites if you are under 18 years of age.
Personal Information That We Collect Through The Websites
When you visit one of the websites, we may collect the following categories of personal information about you:
Details you choose to share with us about yourself (such as your name, email address, or telephone number) when you communicate with us through the websites or by sending us an email to an Angeles Equity Partners email address. For example, if a job applicant clicked on the email address on our “Contact” webpage and emailed us a resume, we may collect the information that the applicant chose to send to us.
Website browsing data such as your IP address, device type, and the pages you visited. Our websites use cookies and/or similar technologies to collect browsing data. Cookies are small data files that we use to track a user’s activity within our websites.
How We Use Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we may use that personal information to respond to your inquiry.
To provide, support, develop our Websites and services, and improve the user experience.
To provide personalized content where available.
To help maintain the safety, security, and integrity of our Websites, services, databases and/or other technology assets, and business. For example, we may analyze use of our websites to protect against misuse or unauthorized use of the websites, to enforce our policies, to identify and prevent fraudulent behavior, or to respond to similar matters.
For testing, research, and analysis, including to develop and improve our Websites and services. For example, we may learn about users’ interactions on our websites to improve the navigability of the websites.
To market our services. If we process your data for direct marketing purposes, you may opt out of receiving direct marketing communications or from having your data processed for direct marketing purposes in the future.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To investigate opportunities and make investments by the fund(s) that we manage.
To evaluate or conduct a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our Website users is among the assets transferred.
As described to you when collecting your personal information.
When you provide us with personal data about yourself or another person, you are confirming to us that you are authorized to provide us with that information and that any personal data you give us is accurate and up-to-date.
Third Parties With Whom We May Share Personal Information
We may disclose personal information to our affiliates, to owners and managers of companies in which we are considering making an investment, and to our employees or consultants, attorneys, accountants, agents, insurers and financial advisors for legitimate business purposes.
We also may disclose information to nonaffiliated third parties under one or more of the following circumstances:
As authorized - for example, as authorized by investor subscription agreements or organizational documents or as otherwise authorized by you or your designated representatives.
As required by applicable law or in connection with regulatory or law enforcement inquiries - for example, to cooperate with regulators during periodic regulatory examinations.
As permitted by applicable law - for example, sharing investor information (i) with companies that maintain, process or service investor or Fund accounts, (ii) with prospective lenders to, or other creditors of, a Fund or a portfolio company in which a Fund has or is considering investing, (iii) in connection with the making, management or disposition of any Fund investment or (iv) as otherwise necessary to effect, administer or enforce investor or Fund transactions.
To provide our services, and for our own disaster recovery and business continuity purposes, we may store or transmit personal data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyze our business.
Among other activities, we may also share information with our lawyers, accountants, custodians and broker-dealers, and with persons otherwise acting in a representative or fiduciary capacity on behalf of investors or us.
We will not give, sell or rent your personal information to third parties for the marketing of their services to you. We also do not provide for advertising from third parties on the websites.
Third parties, such as Google analytics, may collect personal information over time and across different websites when a consumer uses our websites. Please review their privacy policies to better understand their privacy practices. If you choose to click on the “Investor Login” link, you will be taken to a third-party website called Altareturn.com. There, you may choose to enter an email address and a password to log into the Altareturn.com site. If you access the services of another provider, such as Altareturn.com, through our websites or services (for example through a link on the websites) your use of those services is entirely at your risk and governed by the terms and privacy policy of that third party provider. If we resell a service delivered or provided by a third party (“Third Party Service”), including any software that is delivered or owned by a third party (“Third Party Software”), it is that third party’s separate privacy policy that will apply to your personal data and your use of the Third Party Service and Third Party Software. Your use of a Third Party Service is not covered by this policy. Please therefore review the privacy policy for any Third Party Service and Third Party Software before using it.
Data Security
The security of data is very important to our business. We take appropriate technical and organizational measures to protect any personal information that is collected through the websites. However, no method of data transmission or data storage is 100% secure. Although we strive to protect your personal information, we cannot guarantee the security of any information that you send to us.
Handling Of “Do Not Track” Browser Signals
The websites do not use technologies that respond to ‘Do-Not-Track’ signals communicated by your internet browser.
Changes To The Policy
This Policy is subject to change at any time. If we make material changes to the Policy, we will notify you by posting the revised policy to the websites and by including a statement on the homepage of each of the websites stating that the Policy has changed, along with a link to the revised Policy. Your continued use of our websites after we make changes to our Policy is deemed to be acceptance of those changes, so please check this Policy periodically for updates.
Contact Information
Should you have any questions, comments, or concerns about this website Privacy Policy, please contact Annie Chau, our Chief Compliance Officer, at (833) 625-1389 or privacy@angelesequity.com.
Additional information for users located in the european union
This section provides disclosures that apply specifically to data that we process regarding individuals who are located in the European Union (“EU”) or are otherwise subject to the EU’s General Data Protection Regulation (“GDPR”) (collectively “EU Users”). EU Users should also see the information provided above that is applicable to users generally.
Personal Information That We Collect Through The Websites
The information collected by our Websites is described above (See Personal Information That We Collect Through The Websites).
Use of Personal Information
The purposes for which we may use or disclose the personal information we collect is described above (see How We Use Personal Information).
Lawful Grounds for Processing Personal Data
We rely on several lawful grounds for processing your personal information, depending on how you interact with us and/or our Website:
· When Necessary For Us To Enter Into And To Perform A Contract With You. For example, in certain cases, such as in connection with opening an account or making an investment, the provision of personal data may be necessary. Absent such data, we may not be able to provide services to you.
· When You Provide Us With Consent To Process Your Personal Information. For example, if you share your name and contact information to ask a question about our services, we may use that personal information to respond to your inquiry. You may withdraw this consent at any time.
· When Complying With A Legal Obligation. For example, certain laws and/or regulations may require AEP to collect and retain information for a certain amount of time to prevent fraud or other illegal activities.
· We May Also Process Your Personal Information For Our Legitimate Interests. These interests include, but are not limited to,
o improving our services;
o understanding how our customers use our services and Website;
o researching and analyzing the services our customers may want;
o marketing our services;
o researching, measuring, and analyzing the effectiveness of marketing techniques;
o soliciting customer feedback on service satisfaction;
o investigating opportunities and making investments by the fund(s) that we manage; and/or
o keeping our Website safe and secure.
Sensitive Personal Data
Given the nature of our business, we do not typically process “sensitive” or “special categories of personal data,” such as information about health, political opinions, racial origins or sexual orientation, about EU Users. If you are an EU user, please do not send any such information to us unless you explicitly consent in writing to the processing of such data for one or more specified purposes.
Data Retention
We will retain EU Users’ personal data for as long as is necessary for the purposes set forth above unless a longer period is required, by law, or is necessary to resolve disputes, to protect our legal rights, or otherwise to comply with legal obligations. Our retention of data is subject to statutory data retention requirements and/or any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights.
Your Rights
In certain cases, EU Users may have the right to:
Correct or update their data that is inaccurate;
Restrict or limit the ways in which their data is processed;
Object to the processing of their data;
Request deletion of their data;
Obtain a copy of their data in an easily accessible format;
Withdraw their consent; and
Make a complaint to their national data protection authority.
If you wish to exercise any of these rights, you can do so at any time by sending an email to privacy@angelesequity.com.
Automated Decision-Making And Profiling:
We do not engage in automated decision-making or profiling using data about individuals located in the European Union or who are otherwise subject to the GDPR.
Contact Us
The information controller is Angeles Equity Partners, LLC. If you have any question or concern please contact us at 2425 Olympic Blvd., Suite 660E, Santa Monica, CA 90404 or by email to privacy@angelesequity.com. EU individuals have the right, at all times, to lodge a complaint to their national data protection authority, although we would welcome the opportunity to discuss and resolve any complaint with you first.
Additional information for California Residents
This Privacy Notice for California Residents (“California Privacy Notice”) applies to individuals who reside in the State of California (“consumers” or “you”) and whose personal Information we have collected through the Websites. Any terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) have the same meaning when used in this notice. Any capitalized terms not defined in the CCPA have the meaning provided in the Privacy Policy. California consumers should also see the non-EU-user information provided above that is applicable to users generally.
Personal Information Collected (By Categories Set Forth In CCPA). Our websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). Personal information does not include:
· Publicly available information from government records
· De-identified or aggregated consumer information
· Information excluded from the CCPA’s scope, including but not limited to personal information covered by the Gramm-Leach-Bliley Act (GLBA) and health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA).
In particular, our websites have collected the following categories of personal information from its consumers within the last twelve (12) months. Additional information on the personal information we collect is provided above (see Personal Information That We Collect Through The Websites).
Category : Examples Collected
Yes/No - Whether the information is collected
A. Identifiers : real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): name, signature, address, telephone number, education, employment, or employment history. Some personal information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
NO
D. Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
NO
E. Biometric information: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity: Browsing history, information on a consumer’s interaction with a website or application.
YES
G. Geolocation data: Physical location or movements.
NO
H. Sensory data: Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information: Current or past job history.
YES, when voluntarily provided in resumes or related documents sent to us through the website.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO
Use of Personal Information
The purposes for which we may use or disclose the personal information we collect is described above (see How We Use Personal Information).
Personal Information Disclosed For A Business Purpose (By Categories Set Forth In CCPA). During the preceding 12 months, we have disclosed the following categories of personal information about California Consumers (including, but not limited to, customers, job applicants and/or employees) for a business purpose (such as to perform services on our or a service provider’s behalf or to detect or protect against illegal or fraudulent activity):
· Category A: Identifiers
· Category B: California Customer Records Information
· Category F: Internet or other similar network activity.
· Category I: Professional or employment-related information.
We disclose your personal information for one or more business purposes to the following categories of third parties:
· Affiliates;
· Owners and managers of companies in which we are considering making an investment,
· Employees or consultants, attorneys, accountants, agents, insurers and financial advisors for legitimate business purposes.
· Internet cookie data recipients, like Google Analytics
Sales of Personal Information
In the preceding twelve (12) months, we have not sold personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months:
· The categories of Personal Information we collected about you.
· The categories of sources for the Personal Information we collected about you.
· Our business or commercial purpose for collecting or selling that Personal Information.
· The categories of third parties with whom we share that Personal Information.
· The specific pieces of Personal Information we collected about you (also called a data portability request).
· If we sold your Personal Information, the categories of Personal Information that each category of recipient purchased; and
· If we disclosed your Personal Information for a business purpose, the categories of Personal Information that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete, and direct our service providers to delete, your personal information from our records, unless any exception applies. We also reserve the right to deny your request if your personal information is required to:
1. Complete the transaction for which the Personal Information was collected;
2. Provide a service requested by you;
3. Continue the ongoing business relationship with you within the reasonably anticipated context of that relationship;
4. Perform a contract between you and us;
5. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
6. Debug to identify and repair errors that impair existing intended functionality;
7. Exercise free speech, ensure the right of another California resident to exercise his or her right of free speech, or exercise another right provided for by law;
8. Comply with the California Electronic Communications Privacy Act;
9. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws;
10. To enable solely internal uses that are reasonably aligned with the expectations of you based on your relationship with us;
11. Comply with legal obligations;
12. Otherwise to be used internally in a lawful manner that is compatible with the context in which you provided the Personal Information; or
13. Provide employment and related benefits.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and/or deletion rights described above, please submit a verifiable consumer request to us by either:
· Calling us at (833) 625-1389, or
· Emailing us at privacy@angelesequity.com
Only you or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Any disclosures we provide may only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
Our current practice is to not sell your Personal Information for monetary or other valuable consideration and we have not done so in the preceding 12 months. If you are a California resident, you have the right to opt out of having your personal information sold to third parties. If you are a California resident under the age of 16 but at least 13, you have the right to only have your information sold if you opt in and affirmatively authorize the sale of your personal information; if a California-resident child is less than 13, then the child’s parent or guardian must opt in and affirmatively authorize the sale of personal information.
Right of Non-Discrimination
You have a right to exercise your rights under the CCPA without being subject to discrimination, including, but not limited to, by:
· Denying you goods or services;
· Charging you different prices or rates for goods or services;
· Providing you a different level or quality of goods or services; or
· Suggesting you will receive a different price or rate for goods or services or a different level of quality of goods or services.
This right does not prohibit a business from charging a consumer a different price or rate, or from providing a different level or quality of goods or services, if that difference is reasonably related to the value provided to the business by the consumer’s data. In certain instances, we may need your information to provide you with a particular service.
Contact Us
If you have any question or concern please email us at privacy@angelesequity.com or call us toll-free at (833) 625-1389.