Website Privacy Policy

Thank you for visiting the Lovell Minnick website. Your privacy is important to Lovell Minnick and our affiliates (together, ‘our’, ‘us’, or ‘we’). To better protect your privacy, we are providing you information explaining our online information practices.

Lovell Minnick may change this Privacy Policy from time to time, based upon any changes to the personal 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, and if we make any substantial changes to this Privacy Policy, we will post a prominent announcement on our home page of this website. We will use your personal information only in accordance with this Privacy Policy under which the personal information was collected.

Lovell Minnick respects the privacy of visitors to our website. This Privacy Policy describes how and when we gather information from visitors to our website. Please read this Privacy Policy carefully. For the purposes of applicable EU laws, Lovell Minnick will be a data controller of any personal information collected by us.
We rely on various legal bases under applicable data protection legislation in order to process your personal information, including our legitimate interests, contractual necessity and as required by law. We use the personal information 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 information about you, nor any information about criminal convictions and offenses.

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal information, and the possible consequences of you failing to provide such personal information (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations and failure to provide this information means that we cannot provide our services or products to you). In this case, we may have to cancel an investment or service you have with us but we will notify you if this is the case at the time.

Further information about the legal bases under which we process your personal information is included in the section headed “Why We Use Your Personal Information”.

You do not need to take any action as a result of this Privacy Policy, but you do have certain rights as described below in the section headed “Your Rights”.

Aggregate Data

We generally record certain usage information, such as the number and frequency of visitors to this website. This information may include the websites that you access immediately before and after your visit to our website. If we use such data at all, it will be on an aggregated and anonymised basis, and we will not disclose to third parties any information that could be used to identify you personally.

How We Collect Your Personal Information

If you voluntarily submit information to our website, for example, in a request to receive a Lovell Minnick newsletter, we may record and use any such personal information. We may collect personal information from you via the “Contact Us” details on our website (including by email, post and telephone), when you submit a message using our website contact form, or when you provide us your details when signing up for our newsletter. The personal information we may collect about you includes your name, name of your employer, address, title, job title, position, telephone number and email address. Information regarding how we process personal information collected on the Investment Café portal (accessed via the “Client Login” page), is set out in the privacy notice available on the Investment Café portal, or alternatively, the privacy notice provided to you when you invest in one of our funds.
We will only use your personal information for reasonable business purposes as set out below (including, but not limited to, fulfilling your requests). We will not use your personal information for any other purposes without your permission.

Information Provided by Third Parties or Publicly Available Sources

We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. This personal information is obtained via third parties (i.e., the company in question). We may also process information provided to us from recruiters or our portfolio companies in connection with evaluating potential employment or resourcing opportunities.

Why We Use Your Personal Information

To the extent that you provide us with, or we otherwise collect, any personal information, through or in connection with this website (i.e., via telephone, email or post), we may use such information for the following purposes and may process your personal data on more than one legal basis depending on the specific purpose:

Purpose Legal Basis

To provide you with the services or financial products you have requested. Contractual necessity

To keep a record of your relationship with us. Legitimate interest and contractual necessity

To verify your identity. Legal requirement and legitimate interest

To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to. Legitimate interest

Fraud and abuse prevention. Legal requirement and legitimate interest

Litigation management and conducting internal audits and investigations.

Legal requirement and legitimate interest

To administer and protect our business and this website. Legitimate interest
To send you marketing communications. Consent and legitimate interest
To respond to your contact requests via email, post or telephone. Legitimate interest
No automated decision making, including profiling, is used when processing your personal information.

Marketing

We will only send you direct marketing communications, such as Lovell Minnick newsletters, where we have obtained your prior consent to do so, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar services in which you may be interested. You may opt-in to certain kinds of marketing, and amend your marketing preferences at any time (including by unsubscribing), by emailing lovellminnickpartners@lovellminnick.com. You can also click on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

Disclosures and Transfers of Personal Information

We may use internet service providers to operate this website and employ other persons to perform work on our behalf. Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this Privacy Policy, including professional advisors, consultants and data hosting providers, and in some instances, placement agents and other fund administrators. These third parties may have access to the personal information you submit through this website, but only for the purpose of performing their duties. These persons may not use your personal information for any other purpose.

We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards used, please contact lovellminnickpartners@lovellminnick.com.

We will not provide any personal information to any other persons, except if we are required to make disclosures to the government, to comply with a request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us or private parties in connection with a lawsuit, subpoena, investigation, examination or similar proceeding. We reserve the right to disclose any such information in those circumstances. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors.

Protection of Personal Information

We endeavor to protect your personal information. We use both robust technical and procedural methods to maintain the integrity and security of our databases so the information we have about you is protected to the extent possible from unauthorized access and improper use, including firewalls. Please be aware, though, that no security measures are perfect or impenetrable. 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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 Privacy Policy, unless a longer retention period is required by law. 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 lovellminnickpartners@lovellminnick.com.

Capacity

This website is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.

Your Rights

You have the right to access and control (in certain ways) the personal data we process about you. To exercise these rights and controls, please contact lovellminnickpartners@lovellminnick.com.

Your Right Details

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 information you have requested.

Correction You may notify us of changes to your personal data if it is inaccurate or it needs to be updated.

Deletion If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

Restrictions on use If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.

Objection You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.

Portability If you wish to transfer your personal data to another organisation (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 If you previously gave us your consent (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 exercise the above 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. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Thank you for visiting this website. Please contact us at lovellminnickpartners@lovellminnick.com if you have any questions about this website or this Privacy Policy.

Complaints

If you have any concerns, questions or complaints with respect to our processing of your personal information, please contact us at llovellminnickpartners@lovellminnick.com.
You may also lodge a complaint directly with your local data protection authority.

CALIFORNIA WEBSITE PRIVACY POLICY

DATE: December 31, 2019

This California Website Privacy Policy supplements the above Website Privacy Policy 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 above Website Privacy Policy. 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 Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use 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 collect limited types of personal information through our website and investor reporting portals, 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. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
Other customer records, such as telephone number and personal information provided in connection with obtaining account access;
Commercial information, such as account data;
Professional or employment-related information;
Education information;
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. The browsing and/or search history information may include the websites that you access immediately before and after your visit to our website. If we use such data at all, it will be on an aggregated and anonymised basis.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

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:
Information from your communications with us in connection with this Website, including any update notices provided by you.
Information captured on 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 do we use your personal information?

We will use your personal information for one or more of the following business purposes:
To perform services for you.
To improve our Website and the products and services that we offer and notify you about changes to our products and services.
To communicate with you, including responding to requests for information submitted by you through our Website.
To keep a record of your relationship with us.
Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
To audit and verify the quality and effectiveness of our services and compliance.
To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

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 all our marketing emails.

Who do we share your personal information with?

We do not sell 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 administrators, advisors, 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, in response to regulatory inquiries, or upon your request.

Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “What information do we collect about you?”

We may also share your personal information with 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.

How do we keep your personal information secure?

We consider the protection of sensitive 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.
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 with whom we share 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 yes, the categories of personal information that each recipient obtained.

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.

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 using the following toll-free number: 844-250-5175.

Submit a request online using the following online form: www.lovellminnick.com/ccpa.

Email us at the following email address: lovellminnickpartners@lovellminnick.com.

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. 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.

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. Please contact the Chief Compliance Officer of Lovell Minnick Partners LLC at the email address above with any questions about this California Website Privacy Policy