PRIVACY NOTICE

Effective Date: 3 January 2020

Prior Privacy Notice versions are available upon request.

At Adams Street Partners, LLC, we understand that your privacy is an important part of the trust you place in us. This Privacy Notice explains how we collect, use, disclose, and otherwise process Personal Information in connection with our Services. This Privacy Notice is not, however, a contract and does not create any legal rights or obligations.

Who We Are:

Adams Street Partners, LLC is a leading global private markets investment management firm. We are headquartered in Chicago, with operations in New York, London, Tokyo, and other locations around the world.

When we use the terms “Adams Street,” “we,” “us,” or “our” in this Privacy Notice, we are referring to Adams Street Partners, LLC, Adams Street Credit Advisors LP, Adams Street Partners (Beijing) Co., Ltd, Adams Street Partners UK LLP, Adams Street Partners, Inc., Adams Street (Europe) GmbH, Adams Street Partners, LLC (Korea Branch), Adams Street Partners Singapore Pte. Ltd., Adams Street Partners Japan G.K.and their affiliated general partners.

Our Services:

When we use the term “Services” in this Privacy Notice, we are referring to the services that we offer 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.

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”).

Region-Specific Disclosures:

We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

California.

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

Europe.

If you are living in the European Economic Area (“EEA”)that includes for purposes of this notice, all members of the European Union, the UK (if the UK is not a member of the European Union), Liechtenstein, Norway, and Iceland or our processing of your Personal Information takes place in the EEA, please see further below for additional EEA-specific privacy disclosures.

Cayman Islands.

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

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 you. 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 you.

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 Collection

We collect personal information about you in a variety of ways.

Personal Information may be voluntarily submitted by you in the course of using our Services, such as when communicating with us or in the process of requesting and using our Services(e.g., if you register for our Services). In those cases where you directly provide information to us, you are free to choose which information you want to provide to us or whether you want to provide us with information at all. However, some information, such as 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.

Sometimes we collect Personal Information automatically when you interact with our Services, such as passive information collected in our log-files and through the use of cookies and other technologies. Please visit our Cookie Notice for more information on cookies and other technologies.

At times, we may collect Personal Information about you from other sources and third parties, 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.

Current and Prospective Investors

Collection of Personal Information

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.

Use of Personal Information

  • 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, such as 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

Collection of Personal Information

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.

Use of Personal Information

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.

Representatives of Current and Prospective Vendors and Business Partners

Collection of Personal Information

When we explore or choose to contract with a vendor or business partner, we collect Personal Information directly from the vendor’s or business partner’s representatives. This Personal Information may include:

  • Contact Information, such as the representative’s name, email address, and telephone number;
  • Professional/Employment Information, such as the representative’s job title.

Use of Personal Information

We use the information we collect about a vendor or business partner’s representative to:

  • Obtain a vendor’s goods or services;
  • Facilitate and maintain our relationship with the vendor or business partner; and
  • Send email communications about upcoming events.

Other Collection of Personal Information

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 the following information: 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 visit our Cookie Notice.

Other Uses of Personal Information

In addition to the uses of Personal Information identified above, we use the Personal Information we collect to:

  • Facilitate our day-to-day business operations, such as 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, determining the effectiveness of our marketing activities, identifying usage trends, creating financial statements, identifying potential cyber security threats, and personalizing user experience on our Services by presenting tailored information;
  • 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.

Our Disclosure of Personal Information

We disclose Personal Information in the following ways:

  • Within Adams Street: We are able to manage comprehensive investment solutions because of the efforts of our team members across all Adams Street entities. We exchange Personal Information among our affiliates and subsidiaries for purposes and uses that are consistent with this Privacy Notice. For example, we may disclose an investor’s contact information to Adams Street investment professionals in one of our international offices for purposes of their communication with the investor or with other Adams Street personnel.
  • To Our Service Providers: We engage third parties to perform certain functions on our behalf in connection with the use of Personal Information described in the Our Collection and Use of Personal Information section above, including attorneys, accountants, banks, lenders, custodians, insurance brokers, insurance providers, liquidation agents, customer relationship management software providers, IT support providers, due diligence vendors, and placement agents for future fundraising activities.
  • For a Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • In Accordance with Our Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
    • in connection with the establishment, exercise, or defense of legal claims;
    • to comply with laws (such as “Know Your Customer” and anti-money laundering laws) or to respond to lawful requests (including those by law enforcement and regulators) and legal process;
    • to protect the rights and property of us, our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
    • to detect, suppress, or prevent fraud;
    • to reduce credit risk and collect debts owed to us;
    • to protect the health and safety of us, our customers, or any person; or
    • as otherwise required by applicable law.
  • Otherwise with Consent: We may disclose an individual’s Personal Information to certain other third parties with that individual’s consent.

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 13has 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.

We do, however, process Personal Information about children, including names, dates of birth and social security numbers, when it is necessary for the Services we are offering, and you provide it to us. This information is used to provide requested Services.

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

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to notices@adamsstreetpartners.com.

Alternatively, inquiries may be addressed to:

Adams Street Partners, LLC
c/o Legal Department
One North Wacker Drive
Suite 2700
Chicago, IL, USA 60606-2823


SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE

Effective Date: 27 February 2020

Prior versions of this Supplemental California Privacy Notice are available upon request.

Scope of Notice

This Supplemental California Privacy Notice (the “CA Notice”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).

This CA Notice provides additional information about how we collect, use, disclose and otherwise process Personal Information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in this CA Notice have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

Personal Information Disclosures

When we use the term “Personal Information” in this CA Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of this CA Notice, the term Personal Information does not include:

  • Publicly available information from government records.
  • Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
  • Information excluded from the CCPA’s scope, such as:
    • Information reflecting a communication or a transaction between us and a representative of another legal entity in the context of conducting due diligence regarding, or providing or receiving, a product or service to or from that legal entity.
    • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
  • Information relating to our job applicants, employees, contractors and other personnel.

Collection and Use of Personal Information

In the last 12 months, we have collected the following categories of Personal Information from the following sources of Personal Information for the following purposes, which reference the Personal Information, sources and purposes described in the Current and Prospective Investors and Other Collection of Personal Information sub-sections of the Our Collection and Use of Personal Information section of our Privacy Notice:

Category of Personal InformationCollectedCategories of SourcesCommercial or Business Purpose
Identifiers, such as your name, email address, phone number, postal address, investor login username and password, social security number, and passport number
  • Current and prospective investors
  • Individuals who contact us
  • Industry contacts
  • Information providers
  • Publicly available sources
  • Common Purposes described below
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your bank account number, financial account information, and transactions with us
  • Current and prospective investors
  • Common Purposes described below
Protected Classification Characteristics, such as your national origin and citizenship status
  • Current and prospective investors
  • Common Purposes described below
Commercial Information, such as your prior investment experience, subscription information, information about your investments with us or your investments in a broader portfolio
  • Current and prospective investors
  • Industry contacts
  • Information providers
  • Common Purposes described below
Biometric Information
X
Internet/Network Information, such as IP address, device and browser information, clickstream data, log data, and analytics data
  • The browser or device of online visitors
  • Common Purposes described below
Geolocation Data, such as your general geographic location or more precise location when permitted by law
  • The browser or device of online visitors
  • Common Purposes described below
Sensory Information
X
Professional/Employment Information, such as your employer, job title, and compensation
  • Current and prospective investors
  • Individuals who contact us
  • Industry contacts
  • Information providers
  • Publicly available sources
  • Common Purposes described below
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
  • Individuals who contact us
  • Industry contacts
  • Publicly available sources
  • Common Purposes described below
Other Personal Information, such as your net worth, and Personal Information you provide us in relation to a question, request, or inquiry
  • Current and prospective investors
  • Individuals who contact us
  • Industry contacts
  • Information providers
  • Common Purposes described below
Inferences
X

 

In addition to the specific commercial and business purposes identified above, the following “Common Purposes” apply to all categories of Personal Information we collect:

  • To facilitate our day-to-day business operations, such as 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, determining the effectiveness of our marketing activities, identifying usage trends, creating financial statements, identifying potential cybersecurity threats, and providing tailored Services and information;
  • To provide current and prospective investors with information about our firm, their investment, and additional investment opportunities with us;
  • To facilitate investment transactions;
  • To perform due diligence in compliance with “Know Your Customer” and anti-money laundering laws and regulations;
  • To respond to investor inquiries and questions and provide support;
  • To develop new investment strategies;
  • To prevent, investigate, or provide notice of fraud or unlawful or criminal activity;
  • To enforce and carry out contracts and agreements; and
  • To comply with legal obligations.

Disclosure of Personal Information

In the last 12 months, we have not knowingly sold Personal Information about you, but we have disclosed for a business purpose the following categories of Personal Information, which reference the categories of Personal Information described above:

Category of Personal InformationDisclosure for a Business Purpose
Identifiers, such as your name, email address, phone number, postal address, investor login username and password, social security number, and passport number
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as your bank account number, financial account information, and transactions with us
Protected Classification Characteristics, such as your national origin and citizenship status
Commercial Information, such as your prior investment experience, subscription information, information about your investments
Biometric Information
X
Internet/Network Information, such as IP address, device and browser information, clickstream data,
12log data, and analytics data
Geolocation Data, such as general geographic location or more precise location when permitted by law
Sensory Information
X
Professional/Employment Information, such as your employer, job title, and compensation
Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)
Other Personal Information, such as your net worth, and Personal Information you provide us in relation to a question, request, or inquiry
Inferences
X

 

Recipients of Personal Information

As described in the Our Disclosure of Personal Information section of the Privacy Notice, we share Personal Information within Adams Street and with a variety of third parties for business purposes.

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to KnowYou have the right to request any or all of the following information relating to the Personal Information we have collected about you or disclosed in the last 12 months, upon verification of your identity:

  • 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 of the Personal Information we have collected about you;
  • The categories of Personal Information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of Personal Information we have sold about you, and the categories of third parties to whom this information was sold; and
  • The business or commercial purposes for collecting or selling Personal Information about you.
The Right to Request DeletionYou have the right to request the deletion of Personal Information that we have collected from you, subject to certain exceptions.
The Right to Non-DiscriminationYou have the right not to receive discriminatory treatment for exercising any of the rights described above.

However, please note that if the exercise of the rights described above limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

 

How to Exercise Your California Privacy Rights

To Exercise Your Right to Know or Right to Request Deletion

To exercise your right to know and/or right to request deletion, please submit a request by:

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the Personal Information collected in connection with a request to exercise the right to know and/or the right to request deletion to that Personal Information identified to us, certain requests may require us to obtain additional Personal Information from you. In certain circumstances, we may decline a request to exercise the right to know and/or right to request deletion, particularly where we are unable to verify your identity.

Updates to This CA Notice

We will update this CA Notice from time to time. When we make changes to this CA Notice, we will change the “Last Updated” date at the beginning of this CA Notice. If we make material changes to this CA Notice, we will notify you by email to your registered email address, by prominent posting on 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.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to notices@adamsstreetpartners.com.

Alternatively, inquiries may be addressed to:

Adams Street Partners, LLC
c/o Legal Department
One North Wacker Drive
Suite 2700
Chicago, IL, USA 60606-2823


ADDITIONAL EEA PRIVACY DISCLOSURES

Last Updated: 3 January 2020

Prior versions of these EEA Disclosures are available upon request.

Unless otherwise expressly stated, capitalized terms in these Additional EEA Privacy Disclosures (the “EEA Disclosures”)have the same meaning as defined in the Privacy Notice.

Scope of Disclosures

These EEA Disclosures supplement the information contained in our Privacy Notice to comply with the requirements under the General Data Protection Regulation (“GDPR”), but unlike the Privacy Notice, these EEA Disclosures apply only to our processing of your Personal Data where the processing takes place in the European Economic Area(“EEA”) or where the processing of personal data relates to individuals in the European Union, the UK (if the UK is not a member of the European Union), Liechtenstein, Norway, and Iceland-all of which will, for the purpose of this notice, be defined as EEA -and if we either offer goods or services to such individuals or monitor their activities in the EEA.

Adams Street Partners, LLC, Adams Street (Europe) GmbH and Adams Street Partners UK LLP are the data controllers responsible for the collection and use of such Personal Data.

Personal Data Disclosures

When we use the term “Personal Data” in these EEA Disclosures, we mean any information relating to an identified or identifiable natural person.

Legal Bases for Processing

We rely on the following legal grounds to process Personal Data about you, whether it is obtained from you or a third party:

  • The performance of contract (Art. 6 para. 1 lit. b GDPR);
  • The purpose of legitimate interests(Art. 6 para 1 lit. f GDPR) as set out below;
  • Compliance with legal obligations (Art. 6 para. 1 lit. c GDPR); and
  • Consent to the extent provided by an individual (Art. 6 para. 1 lit. a GDPR).

Current and Prospective Investors

Category of Personal DataHow We Use the Personal DataLegal Bases for Processing
Contact Information
  • Provide them with information about our firm, their investment, and our Services;
  • Facilitate investment transactions;
  • Perform due diligence in compliance with “Know Your Customer” and anti-money laundering laws and regulations.
  • Performance of contract;
  • Legitimate interest, namely for customer management and marketing purposes; and
  • Compliance with legal obligations.
Investment Information
  • Provide them with information about our firm, their investment, and our Services;
  • Facilitate investment transactions;
  • Perform due diligence in compliance with “Know Your Customer” and anti-money laundering laws and regulations.
  • Performance of contract;
  • Legitimate interest, namely for customer management; and
  • Compliance with legal obligations.
Professional/Employment Information
  • Provide them with information about our firm, their investment, and our Services;
  • Perform due diligence in compliance with “Know Your Customer” and anti-money laundering laws and regulations.
  • Performance of contract;
  • Legitimate interest, namely for customer management purposes; and
  • Compliance with legal obligations.
Diligence Information
  • Perform due diligence in compliance with “Know Your Customer” and anti-money laundering laws and regulations.
  • Compliance with legal obligations.
Investor Registration and Log-In Information
  • Provide services;
  • Facilitate day-to-day business operations as set out in our Privacy Notice;
  • Develop new investment strategies
  • Performance of contract; and
  • Legitimate interest, namely customer relationship management, to facilitate our day-to-day business as set out in our Privacy Notice, and develop new investment strategies.

 

Representatives of Private Equity Funds and Portfolio Companies

Category of Personal DataHow We Use the Personal DataLegal Bases for Processing
Contact Information
  • 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.
  • Performance of contract;
  • Legitimate interest, namely pursue our business objectives and assess our investments, and customer relationship management; and
  • Compliance with legal obligations.
Professional/Employment Information
  • Communicate with them regarding current or prospective investments 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.
  • Performance of contract;
  • Legitimate interest, namely pursue our business objectives and assess our investments, and customer relationship management; and
  • Compliance with legal obligations.
Diligence Information
  • Communicate with them regarding current or prospective investments 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.
  • Performance of contract;
  • Legitimate interest, namely pursue our business objectives and assess our investments, and customer relationship management; and
  • Compliance with legal obligations.

 

Representatives of Current and Prospective Vendors and Business Partners

Category of Personal DataHow We Use the Personal DataLegal Bases for Processing
Contact Information
  • Obtain a vendor’s goods or services;
  • Facilitate and maintain our relationship with the vendor or business partner; and
  • Send email communications about upcoming client conferences.
  • Performance of contract; and
  • Legitimate interest, namely maintaining the business relationship and marketing.
Professional/Employment Information
  • Obtain a vendor’s goods or services;
  • Facilitate and maintain our relationship with the vendor or business partner; and
  • Send email communications about upcoming client conferences.
  • Performance of contract; and
  • Legitimate interest, namely maintaining the business relationship and marketing.

 

Other Collection of Personal Information

Category of Personal DataHow We Use the Personal DataLegal Bases for Processing
Contact Information
  • Provide services;
  • Respond to inquiries and questions and provide support;
  • For business development purposes and customer relationship management.
  • Performance of contract; and
  • Legitimate interest, namely to respond to inquiries and questions and provide support, to facilitate our day-to-day business as set out in our Privacy Notice, prevent, investigate, or provide notice of fraud or unlawful or criminal activity, enforce and defend against claims.
Automatically gathered information
  • Provide services;
  • For business development including marketing and business analysis purposes as well as customer relationship management.
  • Performance of contract;
  • Legitimate interest, namely to facilitate our day-to-day business as set out in our Privacy Notice, prevent, investigate, or provide notice of fraud or unlawful or criminal activity, enforce and defend against claims, develop new investment strategies and improve our investment offerings; and
  • Compliance with legal obligations.
Information we obtain when communicating
  • Provide services;
  • For customer relationship management;
  • Develop new investment strategies and improve our investment offerings.
  • Performance of contract; and
  • Legitimate interest, namely respond to inquiries and questions and provide support.
Publicly available information
  • Conduct due diligence and risk management relating to our engagement with the investors, private equity fund or portfolio company they represent or invest in.
  • Performance of contract;
  • Legitimate interest, namely to assess our investment; and
  • Compliance with legal obligations.

 

You are not required to provide Personal Data to us, but we do rely on your Personal Data to provide certain Services. For example, we need Personal Data to facilitate investments. If you choose not to provide us with your Personal Data, we may not be able to provide you with a service you request.

Data Retention

We retain Personal Data about you for as long as is necessary for the purposes set out in these EEA Disclosures, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.

The criteria used to determine the period for which Personal Data about you will be retained varies depending on the legal basis under which we process the Personal Data:

Legitimate InterestsWhere we are processing Personal Data based on our legitimate interests, we generally will retain such information for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of data subjects, but no longer than necessary for the purpose for which we process your personal data.
ConsentWhere we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to fulfill the underlying agreement with you or until you withdraw your consent.
ContractWhere we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Legal ObligationWhere we are processing Personal Data based on a legal obligation, we generally will retain the information for the period of time necessary to fulfill the legal obligation.
Legal ClaimWe may need to apply a “legal hold” that retains information beyond our typical retention period where we face threat of legal claim. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.

 

In all cases, in addition to the purposes and legal bases, we consider the amount, nature and sensitivity of the Personal Data, as well as the potential risk of harm from unauthorized use or disclosure of your Personal Data.

International Data Transfers

We may transfer Personal Data about you among our subsidiaries or affiliates, as well as to the categories of third parties identified in the Our Disclosure of Personal Information section of the Privacy Notice. Personal Data may be transferred to, stored and processed in a country other than the one in which it was collected, including, but not limited to, the United States, the Cayman Islands, China, Germany, Japan, Luxembourg, Singapore, South Korea, and the United Kingdom. The country to which Personal Data is transferred may not provide the same level of protection for Personal Data as the country from which it was transferred.

We may transfer Personal Data about you outside the EEA and when we do so, we rely on appropriate or suitable safeguards recognized under the GDPR including adequacy decisions and standard contractual clauses.

Adequacy Decisions

We may transfer Personal Data about you to countries that the European Commission has deemed to adequately safeguard Personal Data.

Standard Contractual Clauses

The European Commission has adopted Standard Contractual Clauses, which provide safeguards for Personal Data transferred outside of the EEA. We may use these Standard Contractual Clauses when transferring Personal Data from a country in the EEA to a country outside the EEA that has not been deemed to adequately safeguard Personal Data. You can request a copy of our Standard Contractual Clauses by contacting us as set forth in the Contact Us section below.

Your Privacy Rights

You have the following rights in relation to your Personal Data (subject to certain limitations at law):

AccessThe right to access Personal Data about you, as well as obtain further information relating to its processing.
RectificationThe right to correct or update any Personal Data about you that is inaccurate or incomplete.
Restriction of ProcessingThe right to require us to limit the purposes for which we process your Personal Data if the continued processing of the Personal Data in this way is not justified, such as where the accuracy of the Personal Data is contested by you.
ErasureThe right to request the erasure of Personal Data about you without undue delay if the continued processing of that Personal Data is not justified.
PortabilityThe right to obtain a copy of Personal Data about you in an easily accessible format and the right to have that data transmitted to another controller.
Objection to ProcessingYou also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your Personal Data, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

 

Please note that if the exercise of these rights limits our ability to process Personal Data, we may not be able to provide our products or Services to you, or otherwise engage with you going forward.

Right to Withdraw Consent

Where we rely on your consent for processing of your Personal Data, you also have the right to withdraw your consent to such processing at any time and with effect for the future, subject to certain limitations at law.

You may withdraw your consent in the following ways:

  • Please contact us as set forth in the Contact Us section below;
  • Where we send marketing communication to you, you may also withdraw your consent by unsubscribing from such communication using the means provided for in each such communication.

Submitting Requests

To submit a request, please contact us as set forth in the Contact Us section below. We may need to verify your identity before processing your request, which may require us to obtain additional Personal Data from you. In certain circumstances, we may decline a request to exercise the rights described above.

Right to Lodge a Complaint

If you have any complaints regarding our privacy practices, you have the right to lodge a complaint with a data protection authority (i.e., supervisory authority).

Updates to These EEA Disclosures

We may update these EEA Disclosures from time to time. When we make changes to these EEA Disclosures, we will change the “Last Updated” date at the beginning of these EEA Disclosures. If we make material changes to these EEA Disclosures, we will notify you by email to your registered email address, by prominent posting on 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.

Contact Us

If you have any questions or requests in connection with this Notice or other privacy-related matters, please send an email to GDPR@adamsstreetpartners.com.

Alternatively, inquiries may be addressed to:

Adams Street Partners, LLC
c/o Legal Department
One North Wacker Drive
Suite 2700
Chicago, IL, USA 60606-2823


CAYMAN ISLANDS PRIVACY DISCLOSURES

FOR OUR INVESTORS IN CAYMAN ISLANDS ENTITIES

Effective Date: 3 January 2020

Scope of Disclosures

These Cayman Islands Privacy Disclosures (the “Cayman Disclosures”) supplement the information contained in our Privacy Notice, but unlike the Privacy Notice, these Cayman Disclosures are made by, and on behalf of, each of our Cayman Islands entities.

Introduction

The purpose of these Cayman Disclosures is to provide you with information on our use of your personal data in accordance with the Data Protection Law, 2017 of the Cayman Islands (the “DPL”). In these Cayman Disclosures, “we”, “us” and “our” refers to Adams Street Partners, LLC, entities domiciled in the Cayman Islands for which Adams Street Partners, LLC or one of its affiliates serves as general partner or investment manager, the general partner and/or investment manager of each such entity and its or their affiliates and/or delegates.

Investor Data

By virtue of making an investment in any of our Cayman Islands entities and your associated interactions with us (including any subscription, capital commitment and/or capital contribution, whether past, present or future) or by virtue of you otherwise providing us with personal information on individuals connected with you as an investor (for example your directors, trustees, employees, representatives, shareholders, investors, clients, beneficial owners or agents), you will provide us with certain personal information which constitutes personal data within the meaning of the DPL (“Investor Data”). We may also obtain Investor Data from other public sources. Investor Data includes, without limitation, the following information relating to you and/or any individuals connected with you as an investor: name, residential address, email address, contact details, corporate contact information, signature, nationality, place of birth, date of birth, tax identification, credit history, correspondence records, passport number, bank account details, source of funds details and details relating to your investment activity.

In our use of Investor Data, the Cayman Islands entity will be characterized as a “data controller” for the purposes of the DPL. The Cayman Islands entity’s affiliates, delegates and service providers may act as “data processors” for the purposes of the DPL.

Who this Affects

If you are a natural person, this will affect you directly. If you are a corporate entity (including, for these purposes, legal arrangements such as trusts, partnerships or limited partnerships) that provides us with Investor Data on individuals connected to you for any reason in connection with your relationship with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.

How We May Use Your Investor Data

Each Cayman Islands entity, as the data controller, may collect, store and use Investor Data for lawful purposes, including, in particular:

  • where this is necessary for the performance of our rights and obligations under the constitutional and operational documents of our entity (together with any subscription agreement or other contract to which you and we are a party);
  • where this is necessary for compliance with a legal or regulatory obligation to which we are subject (such as compliance with anti-money laundering or FATCA/CRS requirements); and/or
  • where this is necessary for the purposes of our legitimate interests and such interests are not overridden by your interests, fundamental rights or freedoms.

Additionally, any of the Cayman Islands entities’ affiliates and/or delegates and/or appointed service providers (the “Delegates”) may use Investor Data, for example to provide its services to us or to discharge the legal or regulatory requirements that apply directly to it or in respect of which we rely upon the Delegates, but such use of Investor Data by a Delegate will always be compatible with at least one of the aforementioned purposes for which we process Investor Data.

Should we wish to use Investor Data for other specific purposes (including, if applicable, any purpose that requires your consent), we will contact you.

Why We May Transfer Your Investor Data

In certain circumstances we and/or our Delegates may be legally obliged to share Investor Data and other information with respect to your interest in a Cayman Islands entity with the relevant regulatory authorities such as the Cayman Islands Monetary Authority or the Tax Information Authority. They, in turn, may exchange this information with foreign authorities, including tax authorities.

We may disclose Investor Data to carry out and implement any and all purposes and objects of our Cayman Islands entity, including: (i) to our Delegates, custodians, banks, financing parties, broker-dealers, accountants, auditors and lawyers, who will either process Investor Data on our behalf or may be data controllers in their own right; (ii) to regulatory, administrative, law enforcement agencies, ombudsmen or other oversight bodies; (iii) to any third party that acquires, or is interested in acquiring, all or a substantial part of our assets or equity interests, or that succeeds our investment manager or general partner in carrying on all or a part of our business; (iv) as required or permitted by law or regulation, including to comply with a subpoena or similar legal process; (v) when we believe in good faith that disclosure is legally required; or (vi) when we have a legitimate interest in making a disclosure and such interests are not overridden by your interests, fundamental rights or freedoms, such as where necessary to protect our investment manager, our general partner or our entity’s rights and property. This may include certain entities located outside the Cayman Islands or the European Economic Area.

The Data Protection Measures We Take

Any transfer of Investor Data by us or our duly authorized Delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL.

We and our duly authorized Delegates shall apply technical and organizational information security measures to protect against unauthorized or unlawful processing of Investor Data, and against accidental loss or destruction of, or damage to, Investor Data.

We shall notify you of any Investor Data breach that is reasonably likely to result in a risk to the interests, fundamental rights or freedoms of either you or those data subjects to whom the relevant Investor Data relates.


COOKIE NOTICE

Effective Date: 3 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 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.