Privacy Policy

Effective Date: October 29th, 2018

SCOPE

This Privacy Policy (“Policy”) describes how Paceline Equity Partners treats personal information on our websites where the Policy is located (the “Platform”).

TYPES OF INFORMATION WE COLLECT

Paceline collects information from you and about you. Here are some examples of the information we may collect:

Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.

Information You Submit. For example, we may collect information when you send us a message through our Platform.
Device Information. For example, we may collect the type of device you use to access our Platform. We may also collect your device identifier, IP address or mobile operating system.
Account Information. Certain portions of the Platform allow you to create a user account. In connection with that account, we may collect your user name and password.
Other Information. If you use our website, we may collect information about the browser you are using.
We might look at what site you came from, or what site you visit when you leave us.

HOW WE COLLECT YOUR INFORMATION

Paceline collects your information in different ways. Below are some examples of how we may collect your information.

Directly From You. For example, when you register for an account or submit an inquiry to us.
Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform.
From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from our business partners, including analytics vendors.
By Combining Information. For example, we may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform.

HOW WE USE YOUR INFORMATION

Examples of how we may use your information include:

To Run and Improve Our Platform and Business. We may use your information to make our Platform and business better. We may also use your information to provide you with information about our business.
To Respond to Your Requests or Questions. This may include responding to your feedback.
To Communicate With You. For example, we may respond to your requests or questions. We may also communicate with you about your account or our relationship.
For Marketing Purposes. We may provide you with information about our company and our business initiatives. For more information about your choices related to these communications, see the Choices section below.
For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.
As Otherwise Permitted By Law or As We May Notify You.

HOW WE SHARE YOUR INFORMATION

We may share your information in the following ways:

Internally. We may share your information with our parent, subsidiary, and affiliate entities.
With Our Business Partners and Service Providers. We may share your information with our business partners. We may also share your information with third parties who perform services on our behalf. For example, this may include companies that help us run our Platform.
With Any Successors to All or Part of Our Business. For example, if we merge with, acquires or is acquired, or sells part of its business to another entity. This may include an asset sale, corporate reorganization or other change of control.
To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might share information when we are investigating a potential fraud.
For Other Reasons We May Describe to You.

CHILDREN UNDER 13

The Platform where this Policy is located are meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 13, and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at info@paceline.com. You can also write to us at the address listed at the end of this website Policy. Please mark your inquiries “COPPA Information Request.”

CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your information. Certain choices you make are browser and device specific.

Marketing Communications:

You can opt out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

Cookies & Other Tracking Technologies:

Your browser may give you the ability to control cookies or other tracking tools. How you do so depend on the type of tool. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

Our Do Not Track Policy:

Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

SECURITY

The Internet is not 100% secure. We cannot promise that your use of our Platform will be completely safe. We encourage you to use caution when using the Internet. We use reasonable means to safeguard personal information under our control. A user id and a password are needed to access certain areas of our Platform. It is your responsibility to protect your username and password.

STORAGE OF INFORMATION

Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.

LINKS

Our Platform may contain links to other third party sites that are not governed by this Policy. If you click on a link to a third party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third party sites.

HOW TO CONTACT US

If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at info@paceline.com. You may also write to us at the following address:

Paceline Equity Partners
3625 N. Hall St.
Suite 900
Dallas, TX 75219
Re: Paceline Privacy Policy

CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.

PRIVACY NOTICE FOR EU INDIVIDUALS

Paceline Equity Partners (“Paceline”) collects personal data about you from your use of this website. We are a controller under the General Data Protection Regulation (“GDPR”) and process Personal Data provided by you through your use of our website. This Privacy Notice explains how we collect Personal Data obtained from you through your use of our website.

1. What Personal Data do we collect?
Personal Data is any information relating to you or that we can otherwise link to you. The Personal Data we collect on this website may include your name, email address, address and other contact information. We may also collect information about your use of the website when you enter and browse the website through the use of “cookies,” web server logs and other electronic tools. This information may include, without limitation, the number and frequency of your visits to the website, the websites accessed before and after you visit the website, the internet browsers used by you and your IP addresses.

2. How do we collect Personal Data?
We collect Personal Data that you voluntarily provide to us, such as through forms you choose to submit to contact us to obtain more information about Paceline. We may also collect Personal Data through the use of a cookie on our website.

This Privacy Notice does not address our privacy practices with respect to any Personal Data we may collect from an investor in funds that we sponsor or manage. We address these practices in separate notices to investors as required by law.

3. How do we use your Personal Data?
We use the Personal Data we collect from you on our website for communication purposes, such as (i) to send you information about Paceline and (ii) to maintain our list of contacts.

4. Why do we process your Personal Data?
We process your Personal Data for communication and marketing purposes.

5. What legal basis do we use to process your Personal Data?
We rely on our legitimate business interests in maintaining business relationships and communicating about Paceline’s business.

6. Is it necessary to provide Personal Data?
You are not required to submit information to us through this website. However, we may collect cookies, which do not require your consent.

7. With whom do we share your Personal Data?
We will not share your Personal Data with third parties except in the context of those third parties acting as data processors. For example, we may use a customer relationship manager software platform to organize our business contacts, and your Personal Data may reside on that software. Where relevant, we will ensure that contractual safeguards are implemented with these third-party data processors to ensure the protection of your Personal Data.

8. How long do we retain your Personal Data?
Your Personal Data will be retained for as long as you are a business contact to us, or longer as required by applicable law. Your Personal Data may be deleted when it is no longer relevant or when you withdraw consent (see below), again within the parameters of applicable law. You may unsubscribe at any time from communications from us, and we will cease sending you further communications.

9. What are my rights with respect to my personal data?
You have the right to know what Personal Data we process about you and have the right to obtain specific information about such Personal Data and to request a copy of your Personal Data, free of charge. You are also entitled to correct or supplement inaccurate Personal Data without delay, unless the request is excessive or unfounded. You have the right to request that your Personal Data be deleted if it is no longer necessary for the purposes it was originally collected or processed, subject to applicable law. You have the right to restrict processing of your Personal Data in some circumstances, subject to any legal obligations of Paceline. You have the right to receive your Personal Data in a machine-readable format and request a transfer of the Personal Data to another party responsible for data processing to the extent that the processing was carried out by automated means. You have the right to object to processing your Personal Data for marketing purposes and the right to opt out of such marketing. You also have the right to lodge a complaint with the relevant data protection authority.

10. What security do we have in place over your personal data?
Paceline has implemented appropriate technical security measures to help protect your Personal Data against loss and to safeguard your Personal Data against access by unauthorized persons. We consider the protection of sensitive information to be a sound business practice, and to that end we employ physical, electronic and procedural safeguards to protect your Personal Data obtained through use on this website.

11. What are our procedures in the event of a breach to your Personal Data?
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data, we will notify the applicable supervisory authority in the European Union within 72 hours of discovering the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons. We will also notify each affected subject of a breach without undue delay if the breach is likely to result in a high risk to the rights and freedoms of natural persons. We are not required to notify you of a breach if the breached data is encrypted, if we have taken measures, such as wiping the data remotely, and such breach is unlikely to result in a material adverse effect, or if providing notice requires disproportionate efforts, in which case a public communication should be made, rather than notice to each person.

12. Updates to this privacy statement
This Privacy Notice was updated in November 2018. We may amend this notice from time to time to reflect changes in our practices with respect to the processing of Personal Data or changes in applicable law.

13. Contact information

If you have any questions about how we process your Personal Data, please contact us at info@pacelineequity.com.