Last Updated: April 2023
If you are from the United Kingdom (“UK”) or European Economic Area (“EEA”), please note that, for the purposes of applicable data protection laws, Searchlight Capital Partners UK, LLP is the data controller of any personal information collected by us while you use the Services. Searchlight Capital Partners UK, LLP is a limited liability company established in the United Kingdom with a registered office at Churchill House, Churchill Way, Cardiff, Wales, CF10 2HH and registered company number OC355364.
The types of information we collect about you.
When you use the Services, we may collect different types of information (including information that US or Canadian privacy laws consider to be “sensitive” or UK/EU privacy laws consider to be “special categories”, denoted by *) about you from three sources: information you provide to us, information we collect through technology, and information we obtain from third parties. Below sets out the information that we collect, and have collected in the preceding 12 months, from these sources.
INFORMATION YOU PROVIDE TO US
In order to obtain access to the Services, you may have to provide information that we collect and store in a way that allows us to relate it to you personally, for example, by contacting us via our Site, email, our “contact us” page, or otherwise, engaging with us regarding investment opportunities and applying for employment. Depending on how you interact with us, such information includes:
- Identifiers, such as basic contact details (e.g., name, mailing address, phone number, e-mail address, facsimile number, company, business contact information), date of birth and the type of investor you are (e.g., analyst, individual, broker).
- Personal information categories listed in the California Customer Records statute, such as name, address, telephone number or form of government ID (e.g., passport number, driver’s license or state identification card number).
- Professional or employment-related information, such as title of profession, employer, or professional background and training, information included in your resume or CV, cover letters, education and academic record, references, qualifications, the ability to work in the country for which you are applying for employment, previous career performance including compensation (to the extent permitted by law) and any other information provided during the application process or your interview.
- Characteristics of protected classifications under US law or sensitive personal information under Canadian law (to the extent you choose to provide it) such as race, sex, age and citizenship and government ID information* (passport number, driver’s license or state identification card number).
- Any other information you choose to provide us, such as past investments, financial records*, conflicts of interest information or any information that you provide in your communications with us.
We process this information to pursue our legitimate interests to be responsive to you, verify your eligibility for, and provide you with, products, Services and investment opportunities, provide personalized assessment of how we can best provide our Services, evaluate your job candidacy and process your employment application, perform our contract with you and maintain our relationship with you.
INFORMATION WE COLLECT THROUGH TECHNOLOGY
We may collect information about you through your computer, mobile phone or other device when you visit our Site, including by means of cookies and other technical methods:
- Internet or other similar network activity, such as information regarding your interaction with the Site and our e-mails, browser type, webpages accessed, traffic patterns and the frequency with which you browse certain parts of the Site.
- Geolocation data, such as IP address (from which we can obtain approximate location information). We may collect your IP address each time you request a page during a visit to the Site or to collect information regarding the frequency with which users browse various parts of the Site.
- Device Information, such as name and type of operating system and mobile network information.
- Security Information, such as a list of certain installed software, device and internet connection information, and available space on your device.
We process this information to pursue our legitimate interests to properly administer the Services, conduct troubleshooting, personalize our Site to ensure content is presented in the most effective manner and maintain the safety and security of our users. Please refer to our Cookies Policy for more information.
Information we obtain from third parties.
Finally, we may obtain information about you from third parties, including publicly available sources and companies that we do business with, investors, referees and recruiters with your consent where required by applicable law. Such information may include:
- Professional or employment-related information, such as any information provided to us by your reference related to your potential employment with us, information about your criminal history provided through a background check or proof of eligibility to work.
- Commercial information, such as information provided to us by business references related to your investment history.
Our use and disclosure of your personal information.
Searchlight does not disclose any personal information about users of the Services to any non-affiliated third party, except as set forth below. This section sets out how we disclose personal information and how we have disclosed, in the past 12 months, the categories of personal information set out above in Section 1. We do not “sell” or “share” (as those terms are defined under the California Consumer Privacy Act) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of California residents under 16 years of age.
We may also store your personal information and share it with our affiliates as necessary for our legitimate interests in order to manage our relationship with you, facilitate your hiring and recruitment process, and provide you with support functions for our Site and Services, including technical infrastructure and customer support.
We may use or disclose your information for Searchlight’s marketing, research and other business purposes with your consent where required by applicable law, and we may associate your personal information with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties.
We may also use service providers, including cloud storage providers, customer relationship management service providers, recruitment and hiring software providers, email and other IT service providers, to facilitate our Services on our behalf as necessary for our legitimate interests or as required by law. These companies and individuals may have access to your personal information, as needed to perform their functions, but may not use it for another purpose.
We will use or disclose personal information when we believe that such disclosures are in our legitimate interests or required by law, rule, regulation, legal process, subpoena, document request or governmental request. For example it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We may also do so to help enforce our Terms of Service, protect your safety or security, including the safety and security of property that belongs to you, or protect the safety and security of our websites, databases or third parties, including the safety and security of tangible or intangible property that belongs to us or to third parties.
Also, in the event that Searchlight, or substantially all of the assets of Searchlight or one or more of its businesses, are acquired or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets. We may transfer all user information (which may include personal information) to our prospective acquirers, sellers, successors or other relevant third parties as necessary whilst negotiating these arrangements or in relation to a change of corporate control in our legitimate interests.
In addition to the foregoing, Searchlight reserves the right to use or disclose any personal information in any manner permitted by applicable law.
How we use your non-personally identifiable information.
Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data (when we collect anonymous information, we maintain it in that form and do not attempt to reidentify it). We may use this information to understand better how the Services are used, research the demographics, interests, and behavior of those who use the Services, improve the Services, provide visitors with customized services and information, tracking recruiting and hiring statistics, monitoring equal employment opportunities, improve our outreach and marketing strategy and for other similar purposes. We may combine this information with personal information. We may share this information with others, such as investors, for information or promotional purposes, and may use this information in any manner permitted by law, but any disclosure that identifies you personally will be governed by Section 2.
Protection and retention of personal information.
We endeavor to protect your personal information. We use technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls. Please be aware though that there is no such thing as “perfect security” on the Internet, and third parties may unlawfully intercept or access transmissions or private communications. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties.
Third Party Sites.
Do not track.
Searchlight does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities 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 should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.
Use of Automated Systems.
We may use both manual and automated systems, such as machine learning and artificial intelligence, to: personalize your experience; automate certain aspects of the Site; and provide you certain features.
The Site is not targeted towards or intended for children, and we do not knowingly collect information relating to children. If you become aware that we have inadvertently collected the personal information of a child, please let us know and we will securely dispose of such information.
Your privacy rights.
Depending on where you live, you may have some of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and in certain cases, we may decline your request as permitted by applicable law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal information.
- Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use your data and who we share it with. If you are a California resident, you have the right to request the following information about our collection, use and disclosure of your personal information:
- categories of personal information we have collected or disclosed for a business purpose;
- categories of sources from which we collected personal information;
- the business or commercial purposes for collecting personal information;
- categories of third parties to whom the personal information was disclosed for a business purpose; and
- specific pieces of personal information we have collected.
- Right to Delete. You may have a right to request that we delete personal information we maintain about you.
- Automated Decision-Making. You may have the right to be informed when your personal information was used to make a decision based exclusively on automated processing of personal information. Upon request, you may be entitled to further information regarding such automated decision-making.
- Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
- Right of Portability. You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party.
- Restriction of processing: You may have the right to require us to stop processing the personal information we hold about you, other than for storage purposes. You may also have the right to restrict the dissemination of your personal information or to request that hyperlinks associated with your name and that provide access to your personal information be de-indexed.
- Objection: You may have the right to object to our processing of your personal information.
- Objection to marketing: You can object to marketing at any time by opting-out from emails using the unsubscribe/ opt-out function displayed in our communications to you.
- Withdrawal of consent: Where we rely on consent to process your personal information, you have the right to withdraw this consent at any time.
You may exercise any of these rights by contacting us using the contact details provided below.
We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
If you have a complaint about how we process your personal information, please contact us at our contact details below and we will respond to your request as soon as possible. If you are located in the UK, and you think we have infringed data protection laws, you can make a complaint with the UK Information Commissioner’s Office. If you are located in Canada and you are not satisfied with our response to a privacy-related matter, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at www.priv.gc.ca or your provincial privacy commissioner.
Searchlight makes no claims that materials on the Site are appropriate or may be downloaded for use in locations outside the United States. Access to the Site from countries or territories where such access is illegal is prohibited. Furthermore, our databases are located in the United States. If you access the Site from outside the United States, you do so at your own risk.
For any transfers of personal information outside the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses) (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact us at the details provided below should you wish to examine a copy of the Model Clauses.
How to contact us.