PRIVACY NOTICE

Last Updated: February 2025

Prior Privacy Notice versions are available upon request.

At Adams Street Partners, LLC (“Adams Street Partners”),1 we understand that your privacy is an important part of the trust you place in us. We have a policy of protecting the confidentiality and security of information we collect about you. This notice (the “Privacy Notice”) explains how we collect, use, disclose, and otherwise process Personal Information in connection with our Services.

This Privacy Notice is intended only for individuals and certain entities that are essentially “alter egos” of individuals (e.g., revocable grantor trusts, IRAs or certain estate planning vehicles). This Privacy Notice is also being provided to you on behalf of, and with respect to, all management companies and fund general partners affiliated with such entities.

Please see below for additional jurisdiction-specific privacy disclosures that may be applicable to you based on your residency.

California

If you are a resident of the State of California in the United States, please see the California Privacy Disclosures for additional California-specific privacy disclosures.

Europe and the United Kingdom

If you are living in the European Economic Area (“EEA”) or the United Kingdom (“UK”), please see the EEA-UK Privacy Disclosures for additional EEA-UK specific privacy disclosures.

Cayman Islands

If you hold an interest in a Cayman Islands entity, please see the Cayman Islands Privacy Disclosures for additional Cayman Islands-specific privacy disclosures.

Singapore

For residents of Singapore, please see the Singapore Privacy Disclosures for additional Singapore-specific privacy disclosures.

Canada

For residents of Canada, please see the Canadia Privacy Disclosures for additional Canada-specific privacy disclosures.

Our Services

When we use the term “Services” in this Privacy Notice, we are referring to the services that we offer, and through which we process, on our own behalf, the Personal Information of:

  • Current and prospective investors;
  • Representatives of and investors in private equity funds and portfolio companies;
  • Representatives of current and prospective vendors and business partners; and
  • Any other person we may interact with when conducting our business as indicated in this Notice.

However, the term “Services” does not include, and this Privacy Notice does not cover:

  • Our processing of Personal Information of our job applicants, employees, or personnel (“HR data”), as the processing of such HR data is addressed in a separate internal Adams Street policy; or
  • Our processing of Personal Information when we are acting as a service provider to other businesses under the California Consumer Privacy Act (“CCPA”).

What is Personal Information

When we use the term “Personal Information” in this Privacy Notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or anonymized information that is maintained in a form that is not capable of being associated with or reasonably linked to an individual. We use the terms “Personal Information”, “PII” and “Personal Data” interchangeably in this Privacy Notice (including the additional jurisdiction-specific disclosures that are incorporated by reference).

Our Collection and Use of Personal Information

The Personal Information we collect, the way we collect it, and how we use it depend on our relationship with you and how you interact with us.

Sources of Personal Information

On a broad level, we collect and maintain Personal Information from the following sources:

  • Information we receive from you in conversations over the telephone, in voicemails, through written correspondence, via e-mail and other electronic communications, or on subscription agreements, investor questionnaires, applications or other forms (including, without limitation, any anti-money laundering, identification and verification documents),
  • Information about your transactions with us or others,
  • Information captured on our website, fund data room and/or investor reporting portal (as applicable), including registration information, information provided through online forms and any information captured via “cookies,” and
  • At times, we may collect Personal Information about you from other sources and third parties, potentially even before our first direct interaction. For example, we may obtain some Personal Information from industry databases or other professionals in the private equity industry. With respect to specific categories of individuals with whom we interact, the following table describes the types individuals and sources of information that we collect as well as how we may use that information:

With respect to specific categories of individuals with whom we interact, the following table describes the types individuals and sources of information that we collect as well as how we may use that information:

Type of Individual Collection of Personal Information Use of Personal Information
Current and Prospective Investors When investors explore our Services or choose to invest with us, we collect Personal Information directly from them, as well as indirectly from third-party service providers or our industry contacts. This Personal Information may include:

  • Contact Information, such as the current or prospective investor’s name, email address, address, and telephone number;
  • Investment Information, such as the current or prospective investor’s subscription information, net worth, prior investment experience, bank account number, and information about his or her transactions, such as capital account balances, contributions and distributions, AUM information and if applicable, individual retirement account information;
  • Professional/Employment Information, such as the current or prospective investor’s employer, job title and compensation;
  • Diligence Information, such as the current or prospective investor’s social security number, passport number, national origin, and citizenship status;
  • Investor Registration and Log-In Information, such as name, contact details, user name, password and IP address and any other information an investor provides us when an inventor registers for our Services or updates information on his or her user account with us.
 We use the Personal Information we collect about current and prospective investors to:

  • Provide them with information about our firm and investments;
  • Facilitate transactions on their behalf;
  • Perform due diligence in compliance with “Know Your Customer” and anti-money laundering laws and regulations;
  • Facilitate day-to-day business operations, including (but not limited to): developing and monitoring private market investments, assisting investors in portfolio management and education, providing financial and accounting support, administering our Services, evaluating and reviewing our business performance, conducting data analytics, and identifying potential cyber security threats.
Representatives of Private Equity Funds and Portfolio Companies When representatives of private equity funds and portfolio companies interact with us on behalf of a private equity fund or portfolio company, we collect Personal Information about them and the private equity fund or portfolio company they represent or invest in, which may include:

  • Contact Information, such as the representative’s name, email address, and telephone number;
  • Professional/Employment Information, such as the representative’s employer and job title;
  • Diligence Information, such as the representative’s employment history, education history, reference information, litigation history, national origin, commentary regarding the representative’s or represented entity’s investment performance, and information about the represented entity’s carried interest splits or succession planning.
 We use the Personal Information we collect about representatives of private equity funds and portfolio companies to:

  • Inform our decisions to invest in the private equity fund or portfolio company they represent or invest in;
  • Conduct due diligence and risk management relating to our engagement with the private equity fund or portfolio company they represent or invest in;
  • Communicate with them regarding current or prospective investments in the private equity fund or portfolio company they represent or invest in;
  • Facilitate and maintain our relationship with the private equity fund or portfolio company they represent or invest in, such as addressing contract amendments, consents, occasional inquiries, securities filings, and portfolio company board activities.
Personal Information from Other Sources and Third Parties

 

 We also obtain Personal Information about the individuals described above from other sources, which we often combine with Personal Information we collect directly from those individuals. We receive the same categories of Personal Information as described above from the following sources and third parties:

  • Industry Contacts: We may collect Personal Information such as name and contact details from other professionals in the private equity industry to perform our due diligence obligations or for business development purposes. For example, we may obtain Personal Information about a general partner from an investor reference.
  • Information Providers: We may from time to time obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain contact information and AUM information from industry databases.
  • Inquiry Information: If an individual chooses to contact us–for example, via email or through the “Contact Us” section of our website –we will collect Personal Information in connection with that individual’s inquiry and correspondence with us which may include the name, email address and phone number as well as the job title and any further content disclosed by the individual. We may need additional information to fulfill the request or respond to the inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request and/or Personal Information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information provided by the individual at that time.
  • Publicly Available Information: We may collect Personal Information such as name and contact details and job title from publicly available sources, such as government records or publicly available websites, to supplement the Personal Information identified above.
  • Information We Collect Automatically: If you merely visit our website, our log files may process information including (but not necessarily limited to the following): IP address, device and browsing information such as browser type, device type, device
    identifiers, screen resolution, device manufacturer and model, internet service provider, referring and exit pages, date/time stamp, clickstream data, and language preferences. Furthermore, we use cookies and other tracking technologies that process personal data. For further information please review our Cookie Notice which is available on our website.
Other Uses of Personal Information Additionally, we may use the Personal Information we collect to:

  • Facilitate our day-to-day business operations (as further detailed above);
  • Respond to investor inquiries and questions and provide support;
  • Develop new investment strategies;
  • Prevent, investigate, or provide notice of fraud or unlawful or criminal activity;
  • Enforce and carry out contracts and agreements; and
  • Comply with legal obligations.

It is important to note that some information, such as (but not limited to) your name, and contact details and information on your requested Services may be necessary for the performance of our contractual obligations. Without providing this information, you will not be able to request or use certain Services or enter into a contract with us.

Our Disclosure of Personal Information

We may disclose any of the categories of Personal Information we collect (i) as permitted by law or regulation, and (ii) subject to appropriate confidentiality agreements, to various affiliates and service providers, including but not limited to, administrators, lenders, banks, auditors, accountants, law firms, tax advisors, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents, in each case as determined necessary and appropriate.

Former Limited Partners and Clients

We maintain Personal Information of our former limited partners and clients and apply the same policies that apply to current limited partners and clients.

Information Security

We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards, which seek to protect your Personal Information in our possession or under our control.

Children’s Personal Information

Our website and online Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 13. If you are under the age of 13, please do not use our website or online Services or otherwise provide us with any Personal Information either directly or by other means. If a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us to request that we remove the Personal Information from our systems. If we learn that any Personal Information we collect has been provided by a child under the age of 13, we will promptly delete that Personal Information.

In certain limited instances, we do collect and process Personal Information about children, including names, dates of birth and social security numbers provided that such collection and processing (i) has been determined to be necessary for the provision of requested Services and (ii) such information was knowingly provided to us.

Third-Party Websites

Our website and online Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Information practices of third parties, please visit their respective privacy notices.

Updates to This Privacy Notice

We reserve the right to change our privacy policies and this Privacy Notice at any time. In the event that we change this Privacy Notice, we will make an updated version of this Privacy Notice available. Depending on our relationship to you, such notice may be provided to you directly by email to your registered email address or by us prominently posting on our website or other online services (such as data sites), or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Further Information

The examples contained within this notice are illustrations only and are not intended to be exhaustive. This Privacy Notice complies with the privacy provisions of Regulation S-P of the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you, including as set forth in our additional privacy notices.

REGION-SPECIFIC DISCLOSURES

California Privacy Disclosures

If you are a resident of the State of California in the United States, please see the California Privacy Disclosures for additional California-specific privacy disclosures.

Europe and the United Kingdom Privacy Disclosures

If you are living in the European Economic Area (“EEA”) or the United Kingdom (“UK”), please see the EEA-UK Privacy Disclosures for additional EEA-UK specific privacy disclosures.

Cayman Islands Privacy Disclosures

If you hold an interest in a Cayman Islands entity, please see the Cayman Islands Privacy Disclosures for additional Cayman Islands-specific privacy disclosures.

Singapore Privacy Disclosures

For residents of Singapore, please see the Singapore Privacy Disclosures for additional Singapore-specific privacy disclosures.

Canada Privacy Disclosures

For residents of Canada, please see the Canadia Privacy Disclosures for additional Canada-specific privacy disclosures.

COOKIE NOTICE

Last Updated: January 2020

Unless otherwise expressly stated, capitalized terms in this Notice have the same meaning as defined in the Privacy Notice.

Scope of Notice

This Cookie Notice supplements the information contained in the Privacy Notice by explaining how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online Services and our communications to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

In some cases, we may use cookies and related technologies described in this Cookie Notice to collect Personal Information, or to collect information that becomes Personal Information if we combine it with other information. For more details about how we process your Personal Information, please review the Privacy Notice.

What Are Cookies and Related Technologies

Cookies are small data files that are stored on your computer that allow us and our third-party partners and providers to collect certain information about your interactions with our email communications, websites and other online Services. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).

What We Collect When Using Cookies

We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications, websites and other online Services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, pages viewed and other similar information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online Services and better understand our customer base.

How We Use That Information

We use or may use the data collected through cookies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our websites and online Services; (b) provide and monitor the effectiveness of our websites and online Services; (c) monitor online usage and activities of our websites and online Services; (d) diagnose errors and problems with our websites and online Services; (e) otherwise plan for and enhance our online Services; and (f) facilitate the purposes identified in the Our Collection and Use of Personal Information section of our Privacy Notice.

Please note that we link some of the Personal Information we collect through cookies with the other Personal Information that we collect about you for the purposes described in our Privacy Notice.

Validity of Cookies

The validity of the cookies used depend on the type of cookie we use. Regarding so-called session cookies that are used temporarily to provide our Services when you use our website, these will only be valid for the time of the session. The validity of other types of cookies depend on each cookie. Google Analytics cookies usually will be active for about 24 months, or until you delete the cookies (please see below for further information on your choices).

Third-Party Cookies

We use the following third parties to support our use of cookies:

  • Google Analytics. We use Google Analytics. Google uses cookies which are text files placed on your computer, to help the website analyze how users use the site. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other Services relating to website activity and internet usage to us. Thus, Google Analytics allows us to better understand how our users interact with our Services. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. We have opted in to Google Analytics’ IP anonymization feature, which instructs Google to anonymize IP addresses prior to storage or processing. Therefore, for individuals in the EEA, your IP address will be shortened by Google in advance within Member States of the European Union or in other Contracting States to the Agreement in the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
  • For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s privacy policy, here. You can also view Google’s currently available opt-out options, including the Google Analytics Opt-Out Browser Ad-On, here. The IP address transmitted by your browser as part of Google Analytics is not combined with other data.

Your Choices About Cookies

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our online Services, as some features and Services on our online Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies. Please note that in the case you delete existing cookies, your chosen pre-settings will be deleted as well. This means that the next time you access our website we may ask for your consent again (to the extent required by law) and set new cookies. The period of validity of those cookies will then start from the beginning.

You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

You can also avoid cookies by not consenting to the use of cookies when asked for consent in cookie banners. You may also withdraw the consent you provided at any time with effect for the future by clicking here.

Updates to This Cookie Notice

We will update this Cookie Notice from time to time. When we make changes to this Cookie Notice, we will change the “Last Updated” date at the beginning of this Notice. If we make material changes to this Notice, we will notify you by email to your registered email address, by prominent posting on this website or our online Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

1. Unless the context otherwise requires, such term is inclusive of all subsidiaries and affiliates of Adams Street Partners, LLC, including but not limited to: Adams Street Partners, Inc., Adams Street Partners UK LLP, Adams Street Partners Singapore Pte. Ltd., Adams Street Partners (Beijing) Co., Ltd., Adams Street Partners Japan Godo Kaisha, Adams Street (Europe) GmbH, Adams Street Canada Ltd., Adams Street Credit Advisors LP, and Adams Street Advisors, LLC and the affiliated general partners of such entities or the general partners of the Adams Street-managed investment vehicles.