Last Updated: June 29, 2022
Note, if you are a Lee Equity employee or investor, our policies and practices regarding the collection and processing of your Personal Information are detailed in Lee Equity’s Employee Privacy Notice and Investor Privacy Statement, respectively.
1. The Information We Collect About You
Over the preceding twelve (12) months, we may have collected the categories of Personal Information listed below about you in connection with your access and/or use of the Site.
A. Information You Voluntarily Provide to Us:
i. Identifiers and Verification Information. To help us respond to requests for data access and/or deletion requests as required by applicable laws, as well as create and maintain a trusted environment, we may collect identity verification information from you, such as images of your government issued ID, passport, national ID card, or driver’s license, as permitted by applicable laws, or other authentication information.
ii. Communications Data. We may collect Personal Information that you provide when you contact us for any reason, such as to express an interest in obtaining additional information about our services, direct questions or concerns about our services to us, use a “Contact Us” form or similar features, sign up for our emails or attend an event, or download certain content.
iii. Employment Information. We may collect Personal Information you provide including job title, company name, work phone number, and work email address.
iv. Characteristics of protected classifications under California or federal law and related identity data. We may collect information submitted as part of a completing online forms on the Site (including, but not limited to, name, age, date of birth, address, gender, nationality, citizenship and contact information).
B. Information from Third Parties.
i. Reputation & Background Check Data. We may collect Personal Information from you and from third parties in connection with performing diligence on job applicants, service providers, and business partners. This data may include contact details, information concerning business practices, creditworthiness, reputation and business history, and job titles or roles.
C. Information Collected Automatically Through the Site, Including Website Data.We may collect and process Personal Information about you when you browse or use certain functions on the Site, which may include the following internet and electronic networking activity information and IT data:
ii. Technical Information. Technical information that we may automatically receive and record from your computer, web browser and/or mobile device, including your IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Site. This includes information about how you use and navigate the Site, including which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions with the Site. When you use the Site on a mobile device, we may also collect the physical location of your device by, for example, using satellite, cell phone tower or wireless local area network signals.
DO NOT TRACK: Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
2. How We Use Your Information
Your Personal Information may be collected, stored, disclosed and processed by Lee Equity for the following purposes:
1. To operate, maintain, enhance, and provide all of the features of the Site;
2. To personalize the Site, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Site;
3. To understand and analyze the usages trends and preferences of our users, to analyze and report on the Site’s traffic, marketing and usage trends, to improve the Site, and to create new features and functionality;
4. For ongoing review and improvement of the information, content and services provided on the Site to ensure it is user friendly;
5. To conduct analysis required to detect malicious data and understand how this may affect your IT system;
6. For in-depth threat analysis, to prevent any potential disruptions such as cyber-attacks, and for statistical monitoring and analysis of current attacks on devices and systems for the on-going adaption of the solutions provided to secure systems and devices against current attacks;
7. To provide you with the products and services for which you subscribe, and to allow you to use and access functionality provided by the Site;
8. To provide you with marketing communications and inform you about news and information relating to our business and services, including new product launches, product updates and general business news (generally, you can opt-out of receiving promotional communications through links provided in the messages or by contacting us directly using the contact information provided below in Section 9);
9. To understand your needs and interests and respond to inquiries, and/or other requests or questions;
10. To detect, investigate and prevent fraud and other crimes or malpractice, and to improve fraud detection and information security;
11. For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), and to obtain legal advice or to establish, exercise or defend legal rights;
12. To confirm and verify your identity and to conduct due diligence;
13. For the management and administration of our business, and to comply with our contractual obligations; and
14. For purposes otherwise set out in this Policy.
3. When We Disclose Information
Lee Equity does not sell or otherwise disclose Personal Information in exchange for monetary or other valuable benefit. We do not share Personal Information with other people or nonaffiliated companies except when we have your permission, as required by law, and/or under the following circumstances:
- We work with third party service providers to provide website development, hosting, data storage, maintenance, and other services for us. To the extent it is necessary for these third party service providers to complete their contractual obligations to us, these third parties may have access to or process information about you. Our third party service providers do not have any independent right to use or share such information outside of their relationship with Lee Equity.
- In some cases, in order to provide the products and services available through and/or in connection with the Site, we provide information about you to trusted partners who work on behalf of or with us under confidentiality agreements. Our partners do not have any independent right to use or share such information outside of their relationship with Lee Equity.
- We may partner with third parties to manage our advertising on other websites. Our third party partners may use tracking technologies to gather information about your activities on our Site and other websites to provide you with advertising based on your browsing activities and interests.
- We may share information about you in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
- We may share information about you if we have a good faith belief that it is necessary to do so in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
- We may transfer or assign information about you if Lee Equity is acquired by or merged with another company, or in the unlikely event of a bankruptcy.
4. Your Rights
Depending on the jurisdiction in which you reside, you may have legal rights in relation to your Personal Information. These rights may include:
- Declining to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the Site.
- Requesting and obtaining information regarding how Lee Equity may use your Personal Information.
- In some circumstances, requesting and receiving some Personal Information about you that you have provided to Lee Equity.
- In some circumstances, requesting that Lee Equity correct your Personal Information if it is inaccurate or incomplete.
- In some circumstances, requesting that we erase your Personal Information (but please note that there may be circumstances where we are legally entitled to retain Personal Information regardless of any such request).
- In some circumstances, requesting that we restrict or block our processing of your Personal Information (again, there may be circumstances where we are legally entitled to refuse that request).
- Where applicable, the right to lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed by Lee Equity.
You can inquire about your rights by contacting us using the details listed below in Section 9.
5. California Privacy Rights
If you are a California resident, you may have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you. Lee Equity does not share Personal Information with third parties for those third parties’ own direct marketing purposes.
The California Consumer Protection Act ("CCPA") provides California residents with certain rights that are in addition to the rights set out in Section 4 above (if you are a California resident, Personal Information will include the full definition of “Personal Information” under the CCPA).
- The right to request, up to twice in a twelve month period, your Personal Information in a format that is portable and, to the extent technically feasible, in a readily useable format that will allow you to transmit it to another entity.
- The right to request that Lee Equity delete your Personal Information, except in circumstances where Lee Equity is legally entitled to retain Personal Information regardless of any such request.
- The right to opt out of any sale of your Personal Information to any third parties, without experiencing any discrimination, as defined under the law, as a result of your exercise of this right. Note that Lee Equity does not sell Personal Information to third parties.
- The right to request that we correct inaccurate and/or outdated Personal information that we maintain about you.
By contacting us regarding any of your rights with respect to your Personal Information, we will not discrimate against you or otherwise deny you access to our products or services. Businesses may not discriminate against consumers who excercise their rights by denying products or services, charging or suggesting different prices of offering different levels or quality of goods or services.
In addition, Cal. Civ. Code § 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
If you are a California resident and you wish to exercise any of the rights enumerated in this section, you may contact us at (877) 690-0204 or by e-mail at email@example.com
6. How We Protect Your Information
- Data Security. We use certain physical, managerial, and technical safeguards that are designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Sites and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Although we may allow you to adjust your privacy settings to limit access to your information, no security measures are perfect or impenetrable. We cannot control the actions of other users or other third parties with whom you may choose to share your information. Therefore, we cannot and do not guarantee that information you post through the Site will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
- Data Retention. We only store your information for as long as may be needed to provide services to you, with the exception of information that we may need to store for a longer period of time to comply with legal or regulatory obligations, resolve disputes, enforce our agreements, or for records management purposes. Lee Equity will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.
- Protecting Children. Our Site and our products and services are intended for use by those over the age of 16. We do not knowingly collect personal information from children under the age of 16. If you are under 16 years of age, then please do not use or access the Sites at any time or in any manner.
7. Disclosures in accordance with Regulation (EU) 2019/2088 Sustainable Finance Disclosures Regulation (the “SFDR”)
Sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment (“Sustainability Risk”). Lee Equity Partners take into account Sustainability Risks as part of their investment decision-making and ESG considerations are integrated into Lee Equity’s investment process.
Lee Equity Partners’ criteria used to determine the remuneration level of employees currently do not take into account Sustainability Risks. Lee Equity Partners may in the future decide to implement certain environmental, social and governance policies which would promote a focus on financial sustainability among their employees (as is relevant to their role).
Lee Equity Partners do not currently consider the adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR. The detailed rules underlying the SFDR will require Lee Equity Partners to ascertain the availability of the data expected to be reported under the new requirements of the SFDR. As such, the position will continue to be monitored and reviewed by Lee Equity Partners as the underlying rules and their application become embedded in the market practice.
8. International Visitors
This Site is controlled and operated by Lee Equity in the United States. If you choose to access the Site from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to provide to you the products and services available through the Site.
9. Other Important Information
- Limitation of Liability. By accessing the Site and/or providing us with Personal Information and other data, you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of such information. In addition, while we take efforts to ensure the proper and appropriate use of data by our service providers that may receive your information from us, we are not responsible for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of your information caused by those service providers.
- Third Party Websites. The Site may provide links to, or features from, other third party websites. If you link to or use such third party sites or features, you do so at your own risk. We do not control and are not responsible for the content or practices of any third party website, application, or other product or service.
10. Our Contact Information