Spectrum Equity

California Consumer Privacy Act Privacy Notice

Last Updated: December 10, 2024

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in Spectrum Equity Management L.P.’s Privacy Policy (the “Policy”) and applies solely to individuals who reside in the State of California (“consumers” or “you”). This Notice describes how we collect, use, and share personal information of consumers when we act as a “business” as defined under the California Consumer Privacy Act (“CCPA”), and their rights with respect to their personal information. For purposes of this Notice, “personal information” has the meaning given under the CCPA but does not include information exempted from the CCPA.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Please refer to Spectrum Equity’s California Personnel and Job Applicant Notice, which may be found here.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We will collect, and in the past twelve (12) months have collected, the categories of personal information listed in the table below. For more details about the personal information we collect, please refer to the section of our Policy titled “WHAT PERSONAL INFORMATION IS COLLECTED?”.

Category A: Identifiers
Examples: May include, for example, first and last name, alias, postal address, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: May include, for example, name, address, telephone number, or employment information. Some personal information included in this category may overlap with other categories.

Category C: Protected classification characteristics under California or federal law.
Examples: May include information that you choose to provide in your communications with us, for example, age (40 years or older), sex (including gender, gender identity, or gender expression), or veteran or military status.

Category D: Commercial information.
Examples: May include, for example, records of investment or business interests, histories, or tendencies.

Cateogory E: Internet or other similar network activity.
Examples: May include, for example, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Category F: Sensory data.
Examples: May include, for example, audio, electronic, visual, or similar information.

Category G: Professional information.
Examples: May include, for example, job title, place of work, and other professional details.

Category H: Inferences drawn from other personal information.
Examples: May include, for example, profile reflecting a person’s preferences based on other personal information listed above.

CATEGORIES OF SOURCES OF PERSONAL INFORMATION

We obtain the categories of personal information listed above from the following categories of sources:

  • Personal information collected directly from you. For example, from forms you complete or products and services you purchase.
  • Personal information collected automatically. For example, from observing your actions on our Site.
  • Personal information from third parties. For example, third party vendors that provide databases or referral sources.

These sources are described more fully in the section of our Policy titled “WHAT PERSONAL INFORMATION IS COLLECTED”?

PURPOSES OF COLLECTION AND USE OF PERSONAL INFORMATION

The business or commercial purposes for which we collect and use (and in the preceding twelve (12) months may have collected and used) personal information are described in full in the section of our Policy called “HOW IS PERSONAL INFORMATION USED?”. By way of example, these purposes may include the following:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. We may also save your information to facilitate future communications and services.
  • To provide, support, personalize, and develop our Platform, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our Platform, products and services, databases and other technology assets, and business.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.

To the extent that we may collect sensitive personal information (as defined under the CCPA), we only use or disclose it for purposes permitted under the CCPA (e.g., to provide the Platform, to detect security incidents and prevent fraud, or to verify and maintain the quality of the Platform). We do not collect or use sensitive personal information for the purpose of inferring characteristics about California residents.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information for any of the business purposes described above. When we disclose personal information for a business purpose, we make efforts to ensure that the recipient will both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months we may have disclosed all the categories of personal information listed above to the following categories of recipients:

  • Related companies.
  • Service providers, including firms that provide assistance in servicing Spectrum and that have a need for such information, such as CRMs or other service providers.
  • Limited partners, portfolio companies, and other business contacts.
  • Law enforcement, government authorities, or others.
  • Business transaction participants.
  • Professional advisors.

These recipients are described in more detail in the section of the Policy titled “HOW IS PERSONAL INFORMATION DISCLOSED?”

As of the “Last Updated” date at the top of this Notice, we do not sell personal information for monetary or other valuable consideration, and do not share personal information for purposes of cross-context behavioral advertising purposes. This has also been the case in the preceding twelve (12) months.

YOUR CALIFORNIA PRIVACY RIGHTS

California privacy laws provide California residents with specific rights regarding their personal information. This section describes your rights and explains how to exercise them.

Right to Know. You have the right to request that we disclose the following:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The business or commercial purpose for collecting, selling, or sharing that personal information;
  • The categories of third parties to whom we disclose that personal information; and
  • The specific pieces of personal information we have collected about you.

Right to Delete. You have the right to request that we delete personal information collected from you.

Right to Correct. You can ask us to correct inaccurate personal information that we maintain about you.

Right to Nondiscrimination. You have a right not to receive retaliatory or 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 the Platform or engage with you in the same manner.

“Shine the Light” Requests. Under California’s “Shine the Light” law, residents who have an established business relationship with us are entitled to ask us for a notice describing what categories of personal information we share with third parties for the third parties’ direct marketing purposes, if any. To submit a request, please email us at compliane@spectrumequity.com with “Shine the Light” in the subject line.

To request to exercise the rights to know, correct, or delete described above, please submit a request to us by either:

  • Calling us at 1-415-464-4600
  • Emailing us at compliance@spectrumequity.com

When submitting a request, please:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include an email address that operates as a user log-in with Spectrum, name, and date of birth.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity and confirm the personal information relates to you. This is a security measure to, for example, ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response, and we reserve the right to confirm your California residency.

Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

Any disclosures we provide may only cover the applicable period required by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

You may also designate an authorized agent to make a request on your behalf. If you do so, we may require proof that you gave the agent signed permission to submit the request. In some cases, we may also require you to verify your identity directly with us, to directly confirm with us that you provided the authorized agent with permission to submit the request, or to take other steps required or permitted by the CCPA.

RETENTION

For information about our data retention practices in relation to personal information, please review the section of our Policy titled “RETENTION OF PERSONAL INFORMATION.”

DO NOT TRACK
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

CHANGES TO THIS NOTICE
We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Site and update the Notice’s “Last Updated” date. Your continued use of our Platform following the posting of changes constitutes your acceptance of such changes.

CONTACT INFORMATION
If you have any questions or comments about this Notice, the ways in which we collect and use your information described here and in the Policy, your choices and rights regarding such use, or you wish to exercise your rights under California law, please do not hesitate to contact us at:
Phone: 1-415-464-4600
Email: compliance@spectrumequity.com