Privacy Policy

Effective Date: June 1, 2023
Last Reviewed on: June 1, 2023

For all California residents, please refer to Spectrum Equity's California Consumer Privacy Act Privacy Notice, which may be found here.

For all California residents that are employees, contractors and job applicants of Spectrum Equity Management, L.P., Spectrum Management Equity, Inc. and its affiliates, please refer to Spectrum Equity’s California Personnel and Job Applicant Notice, which may be found here.

For all UK residents that are employees, contractors and job applicants of Spectrum Equity UK, LLP and its affiliates, please refer to Spectrum Equity’s UK GDPR Personnel and Job Applicant Privacy Notice, which may be found here.

Spectrum Equity knows that your privacy is important to you, and we want you to know that it is important to us too. We created this Policy to explain the types of information we collect through www.spectrumequity.com and the various social networking platforms that we use (each, a “Site”), as well as more broadly such as when you provide information to us over the phone or via other means of communication, how we will use, disclose and protect this information once it is collected, and how you can opt-out of some of our uses and disclosures of your information. This Policy does not apply to our limited partners, who can find their EEA/UK Privacy Notice or their Regulation S-P Privacy Notice in the Restricted Website.

Here are a few general principles to keep in mind as you read through this Policy:

  • The Site is owned and operated by Spectrum Equity Management, L.P. and its affiliates (referred to collectively in this policy as “we,” “us,” and “our”). The UK entity and controller of Personal Information (defined below) relating to a natural person located in the UK (a “Data Subject”) is Spectrum Equity UK, LLP, which is an affiliated company of Spectrum Equity Management, L.P.
  • As our business evolves, this Policy may change, so check back to this page periodically to make sure you understand how your Personal Information will be treated.

What information is collected?

“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect different categories of Personal Information from different sources, including user-provided information and site usage information. We also collect Personal Information from social networking and blogging.

User-Provided Information

We collect Personal Information such as your name; company name; e-mail addresses; telephone numbers; ISP account addresses (including text message addresses); and site browsing history. For example, we may collect Personal Information such as your e-mail address, or any other information you may choose to provide, when you submit a comment or question to us through the Site. We may also collect names or other types of Personal Information from you when accessing the Restricted Website (as defined in the Terms of Use) to help verify that you are authorized to access the Restricted Website.

Social Networking
We maintain a presence on social networking and blogging platforms, some of which are operated by third parties, such as LinkedIn. This Policy applies to our use of information you submit to us there, but it does not apply to what those third party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.

How is your information used?
We or our service providers may use the Personal Information we collect from and about you, including User-Provided Information, Site Usage Information (please refer to our Cookie Policy for further information about Site Usage Information) and/or any information collected through Social Networking sites, to perform the following business functions:

  • enabling users to use our Site and its features
  • administering the Site and your account with us, including verifying approved access to the Restricted Website
  • responding to your requests, questions, and concerns
  • market research and better understanding our audience
  • developing new features and offerings on the Site
  • increasing the functionality and user-friendliness of the Site
  • protecting our rights and property
  • recovering debt and preventing fraud
  • other purposes disclosed when Personal Information is submitted to us
  • or job applicants and employees, how we use your Personal Information is set out in our Personnel and Job Applicant Privacy Notices;
  • for potential investors, we will use your Personal Information to assist with any queries you may have; and
  • any Personal Information from individual contacts we have relating to businesses in which we invest will be used to fulfil that business relationship.

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

Do we share Personal Information and Site Usage Information with others?

Yes. We may share the information we collect on the Site with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf), we may share your information; and

  • when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law.
  • in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business. In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

Legal Basis for Processing Personal Information

We use the Personal Information collected from Data Subjects where it is necessary for us to perform under an agreement with you (if we have one with you) and for our legitimate interests where your interests and fundamental rights as a Data Subject do not override those interests. For example, in order for us to operate our Website, it is necessary for us to collect certain data about you to improve your user experience and manage the Site. In addition, we use this Personal Information to send informational messages to you to the extent allowed by applicable law.

Disclosure & Retention of Data Subjects’ Personal Information

We will take reasonably necessary steps to ensure that where Personal Information of Data Subjects is shared with third parties, it is treated securely and in accordance with this Policy and applicable laws.

We will endeavour not to keep Personal Information in a form that allows a Data Subject to be identified for any longer than is reasonably necessary for achieving the permitted purposes. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymize Personal Information as part of such efforts. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the data subject’s Personal Information, the purposes for which we process the data subject’s Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Storage & Transfer of Data Subjects’ Personal Information

We maintain physical, electronic and procedural safeguards designed to protect Data Subjects’ Personal Information, prevent unlawful or unauthorised processing of Personal Information, and prevent unauthorized disclosure of, or accidental loss of, or damage to, such information.

We may process Personal Information in, and transfer personal information to, countries that may not guarantee the same level of protection for Personal Information as the country in which Data Subjects reside. When doing so, we will seek to ensure that appropriate safeguards are in place to protect the Personal Information.

Personal Information will also be processed outside the European Economic Area. This includes employees engaged in, among other things, the provision of administration and support services. All such staff are subject to reasonably appropriate confidentiality and security obligations.

We restrict access to non-public Personal Information about Data Subjects to those of our employees and agents who need to know the information to enable us to provide services.

We will only transfer Personal Information to third party service providers if they agree to comply with the physical, electronic and procedural safeguards described above, or if they put in place adequate measures themselves.

Data Subect Under European Law

If you are a Data Subject, you may have certain rights in addition to those described elsewhere in this Policy. These rights are in relation to your Personal Information, and include the right to be informed about the collection and use of your Personal Information, as outlined in this Policy.
Such rights may also include, where certain conditions are met:

  • the right to request access to the Personal Information we hold about you,
  • the right to have inaccurate information about you amended or updated,
  • the right to object to processing of Personal Information about you,
  • the right to withdraw consent at any time (where we rely on your consent to process your Personal Information),
  • the right to have Personal Information about you erased or to restrict processing in certain limited situations,
  • the right to data portability and to request the transmission of Personal Information about you to another organization,
  • the right to object to automated decision making that materially impacts you, direct marketing, and processing for research or statistical purposes, and
  • the right to lodge complaints with applicable data supervisory authorities.

As a Data Subject, you should use the contact information below to get more information and/or to make a formal request. We will endeavor to keep the Personal Information we store about you accurate and up-to-date by enabling you to correct it by request. You should notify us if any of your Personal Information changes or if you become aware of any inaccuracies in the Personal Information we hold about you.

Security

While we endeavor to protect the security and integrity of all information collected via this Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely error-free or safe from intrusion by others, such as hackers. We do not warrant or represent that the Site’s level of security meets or exceeds any particular standard, and any information you submit via the Site is at your own risk.

If you correspond with us by e-mail, text message, or using Web forms like a “contact us” feature on our Site, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

“Linked-To” Web Sites

The Site may contain links, banners, or widgets that lead to other Web sites. We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each Web site visited after leaving the Site to learn about how your information is treated by others.
In particular, the Restricted Website is maintained by a third-party service provider who may have its own privacy policy. We encourage you to review the policies that are applicable to the Restricted Website. We are not responsible for any such policies.

Changes to this Privacy Policy
We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.

Contact Us
If you have any questions or comments regarding our privacy practices, you may contact us at:
Spectrum Equity Management, L.P.
One International Place, 35th Floor
Boston, MA 02110
U.S.A.
Email: compliance@spectrumequity.com
Phone: 1-617-464-4600