Last Updated December 7, 2018
Applicability Of The Policy
This policy applies to any personal data that you provide to us or we collect about you through the website.
For purposes of this policy, an affiliate is an entity that (i) controls the funds we directly or indirectly manage (the “Funds”), (ii) is controlled by the Funds, or (iii) is under common control with the Funds. Nonaffiliated third parties are parties who are not affiliates of the Funds.
It applies specifically, but not exclusively, to the websites www.angelesequity.com, www.angelesequitypartners.com, and any other websites owned, operated or provided by Angeles Equity Partners (collectively, the “websites” or individually, the “website”).
Persons Under 18 Years Of Age
We do not market to or enter into contracts with children nor do we intend to collect personal data from any person under 18 years of age. Please do not access or use any of the websites if you are under 18 years of age.
Categories of Personally Identifiable Information That We Collect Through The Websites
When you visit one of the websites, we may collect the following categories of personally identifiable information about you:
Details you choose to share with us about yourself (such as your name, email address, or telephone number) when you communicate with us through the websites or by sending us an email at the contact email address listed on one of the websites. We may use such information in a manner that is customary for businesses in such circumstances, such as to respond to your questions or to communicate with you about Angeles Equity Partners or our services; and
When you provide us with personal data about yourself or another person, you are confirming to us that you are authorized to provide us with that information and that any personal data you give us is accurate and up-to-date.
Third Parties With Whom We May Share Personally Identifiable Information
We may disclose personally identifiable information to our affiliates, to owners and managers of companies in which we are considering making an investment, and to our employees or consultants, attorneys, accountants, agents, insurers and financial advisors for legitimate business purposes.
We also may disclose information to non-affiliated third parties under one or more of the following circumstances:
As authorized - for example, as authorized by investor subscription agreements or organizational documents or as otherwise authorized by you or your designated representatives.
As required by applicable law or in connection with regulatory or law enforcement inquiries - for example, to cooperate with regulators during periodic regulatory examinations.
As permitted by applicable law - for example, sharing investor information (i) with companies that maintain, process or service investor or Fund accounts, (ii) with prospective lenders to, or other creditors of, a Fund or a portfolio company in which a Fund has or is considering investing, (iii) in connection with the making, management or disposition of any Fund investment or (iv) as otherwise necessary to effect, administer or enforce investor or Fund transactions.
To provide our services, and for our own disaster recovery and business continuity purposes, we may store or transmit personal data to or through third party providers, such as with our contractors and advisors to help us operate, secure and analyze our business.
Among other activities, we may also share information with our lawyers, accountants, custodians and broker-dealers, and with persons otherwise acting in a representative or fiduciary capacity on behalf of investors or us.
We will not give, sell or rent your personally identifiable information to third parties for the marketing of their services to you. We also do not accept advertising from third parties on the websites.
Information Safeguarding Policy
The security of data is very important to our business. We take appropriate technical and organizational measures to protect any personally identifiable information that is collected through the websites. However, no method of data transmission or data storage is 100% secure. Although we strive to protect your personal information, we cannot guarantee the security of any information that you send to us.
We may create anonymized data from personal data. Anonymization may, for example, be achieved by aggregating data to the point that no individual can be identified such as aggregating website use statistics to see what web content is working well and what could be improved. Anonymized data does not allow for the identification of any individual person and, as it is no longer personal data, this policy does not apply to such data.
‘Do Not Track’
The websites do not use technologies that respond to ‘Do-Not-Track’ signals communicated by your internet browser.
Changes To The Policy
Additional Information for users located in the European Union
This section provides disclosures that apply specifically to data that we process regarding individuals who are located in the European Union (“EU”) or are otherwise subject to the EU’s General Data Protection Regulation (“GDPR”) (collectively “EU Users”). EU Users should also see the information provided above that is applicable to users generally.
Processing Of EU Users’ Personal Data
Our legal basis for collecting and processing personal data under the GDPR will depend on the personal data concerned and the specific context under which it is processed. In most cases, the lawful ground will be that the processing: (i) is necessary for our legitimate interests in carrying out our business, including to raise and invest in our Funds as well as maintain, improve and market our products and services, provided those interests are not outweighed by your rights and interests (“Legitimate Interests”), (ii) is necessary to perform a contract with you (“Contractual Necessity”), or (iii) is necessary to comply with our legal obligations (“Legal Obligation”). Where processing is based on your affirmative consent (“Consent”), it will be apparent that this is the basis for processing because you will be asked for your consent.
We use personal data in the normal course of our business, for example:
To respond to inquiries about our services, to provide the websites and services, and to provide advice and support. Our lawful bases for these categories of use include Legitimate Interests and, in some cases, Contractual Necessity or Consent. In certain cases, such as in connection with opening an account or making an investment, the provision of personal data may be necessary. Absent such data, we may not be able to provide services to you.
To analyze and improve the websites, the services, (for example for technical or security purposes) and to improve the customer experience. We may use browsing information to allow us to measure user trends (such as which domains refer users to our site), to provide personalized content where available, to help diagnose problems, to verify or enforce compliance with the policies governing our site and protect against misuse or unauthorized use of our website, to administer this website more effectively and to gather broad geographic information about where users are accessing our site from. Our lawful basis for this category of use is Legitimate Interests.
To market our services. Our lawful basis for this category of use is Legitimate Interests and, in some cases, Contract. If we process your data for direct marketing purposes, you may inform us that you object to such processing and opt out of receiving direct marketing communications or from having your data processed for direct marketing purposes in the future.
To investigate opportunities and make investments by our fund(s). Our lawful basis for this category of use is Legitimate Interests.
In certain circumstances, to share it with a limited number of third parties as described in this policy, for example for operational requirements and business continuity purposes. Our lawful basis for this category of use is Legitimate Interests and, in some cases, contract or consent.
Sensitive Personal Data
Given the nature of our business, we do not typically process “sensitive” or “special categories of personal data,” such as information about health, political opinions, racial origins or sexual life, about EU Users. If you are an EU user, please do not send any such information to us unless you explicitly consent in writing to the processing of such data for one or more specified purposes.
We will retain EU Users’ personal data for as long as is necessary for the purposes set forth above unless a longer period is required, by law, or is necessary to resolve disputes, to protect our legal rights, or otherwise to comply with legal obligations. Our retention of data is subject to statutory data retention requirements and/or any valid opt-out or withdrawal of consent where processing is based on consent, or other valid exercise of your data subject rights.
In certain cases, EU Users may have the right to:
Correct or update their data that is inaccurate;
Restrict or limit the ways in which their data is processed;
Object to the processing of their data;
Request deletion of their data;
Obtain a copy of their data in an easily accessible format;
Withdraw their consent; and
Make a complaint to their national data protection authority.
If you wish to exercise any of these rights, you can do so at any time by sending an email to email@example.com.
Automated Decision-Making And Profiling:
We do not engage in automated decision-making or profiling using data about individuals located in the European Union or who are otherwise subject to the GDPR.
The information controller is Angeles Equity Partners, LLC. If you have any question or concern please contact us at 2425 Olympic Boulevard - Suite 660E, Santa Monica, CA 90404 USA or by email to firstname.lastname@example.org. EU individuals have the right, at all times, to lodge a complaint to their national data protection authority, although we would welcome the opportunity to discuss and resolve any complaint with you first.