CCPA Privacy Notice
Last Revised: June 30, 2023
CCPA Privacy Notice
THE CCPA AND YOUR PERSONAL DATA RIGHTS
The California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA) grants California residents increased control over their personal information.
Defining Personal Information
Various laws and regulations (including the CCPA) use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories. The CCPA sets out obligations and rights in relation to “personal information”, meaning information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
Types of Collected Personal Information
ECP collects some personal information about you. This section describes the categories of personal information that are collected, as well as the categories of sources for obtaining that personal information, and the purpose for collecting it.
Personal Information Categories-
The personal information we collect from you and have collected from you over the past 12 months consists of the following categories:
• Identifiers: Full name, home and/or business address, telephone number, and other contact information
• Internet or other electronic network activity information: IP address, operating system and browser, your interactions with our website, and websites you visit before and after ours
• Professional or employment-related information: Information gathered for purposes of securing at will employment at ECP, information in your resume or cover letter such as educational history and professional background, background checks of education and former employers, credit reports, civil/criminal activity reports
• Other personal information you voluntarily provide to us.
Sources of Personal Information
We obtain, and in the past 12 months have obtained, personal information directly from you, our affiliates, portfolio companies and other service providers, including by example, underwriters, brokers, trustees, legal advisors and accountants.
If you apply for employment at ECP, we also obtain and have obtained in the past 12 months information from third parties that you authorize us to contact or receive information from.
Purpose for Collecting Your Personal Information
We collect your personal information to:
• Contact and communicate with you or your designated representative by phone, email, fax, or mail
• Provide you with products and services, enhance user experience, and analyze trends
• Internal marketing and research
• Provide you or your representative with marketing communications
• Share information about our services including investment research
• Comply with applicable legal and regulatory obligations and to protect or defend the ECP Site, our rights and the rights of others
• Manage job applications and employment at ECP
You may elect not to provide us with information, but doing so may prevent us from providing you with services you may request. If you are currently receiving information or marketing communications from us, however, you may opt-out of receiving further communications at any time using one of the contact methods listed below.
Disclosing Your Personal Information
We do not sell or share personal information about you, as those terms are defined by the CCPA, to third parties and have not done so in the past 12 months. We do not have actual knowledge that we sell or share personal information of individuals under 16 years of age.
We disclose and have disclosed in the past 12 months the categories of personal information outlined in the “Types of Collected Personal Information” section above:
• Within ECP and our affiliates and subsidiaries for data processing or storage purpose
• With business partners and service providers such as our data analytics providers our cloud services provider and our CRM provider to help operate our business and send marketing and other communications
• To comply with applicable law, subpoena or other judicial process, to respond to summons or other requests from law enforcement, government authorities, judicial orders or other third parties and to exercise or defend legal claims
• In connection with, or during negotiations of, any merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our business, which may involve us disclosing information to other corporate entities, professional advisors and other third parties in connection with such activities
• In connection with our receipt of professional services, which may involve us disclosing information to professional advisors, including our lawyers, accountants and auditors with your consent or direction
Retention of Personal Information
We retain personal information, including sensitive personal information, as long as we need it to provide access to our website, products, and services, communicate with you, comply with legal obligations, or protect our or other’s interests. We decide how long we need information on a case-by-case basis.
The CCPA provides you with certain rights in regard to what we do with your personal information. This section details those rights, how to exercise them, and what ECP will do in response.
You have the right to request that we disclose to you, free of charge, the categories and specifics of the personal information we collect about you. We require a verifiable request from you to ensure that it is, in fact, you or someone authorized to act on your behalf who is requesting such a disclosure. Once we verify the request, we will provide that information to you. We may request specific information from you (such as a copy of your government issued ID) to help us confirm your identity and process your request. An authorized agent may make a request on your behalf by providing written permission signed by you.
Your request for disclosure can apply to any such personal information mentioned in the previous paragraph for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the personal information we collect about you more than twice in a twelve-month period.
Following our verification of your request, we will disclose to you, unless ECP is permitted to deny your request or is otherwise restricted by law or regulation:
- The specific pieces of personal information we have collected about you
- The categories of personal information we have collected about you
- The categories of sources from which the personal information is collected
- The business or commercial purpose for collecting that personal information
- The categories of third parties with whom we shared the personal information
Deletion of Personal Information-
Where provided by law, you have the right to request that we delete the personal information we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your personal information in our possession that we collected from you, unless ECP is otherwise legally permitted to retain or is otherwise restricted by law or regulation.
Right to Correct-
You have the right to request that we correct inaccurate personal information that we maintain about you, following our verification request. We have included our contact information below in the event you would like your information updated.
Non-Discrimination for Exercising Your Rights-
We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.
Contacting Us to Exercise Your Rights
You may contact us in order to exercise any of your rights set forth in this privacy notice by calling this toll-free number 1-866-890-3270 or by contacting the ECP compliance team at firstname.lastname@example.org.