MDP WEBSITE PRIVACY POLICY

Last modified: January 2020

MDP’s Commitment to Your Privacy

This website privacy policy (the “Privacy Policy”) applies to www.mdcp.com (the “Website”), which provides information about Madison Dearborn Partners, LLC and its affiliated entities commonly referred to as “MDP”. This Privacy Policy only applies to information MDP may collect from visitors to the Website. If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement”.

Information We Collect

The Website does not directly collect any of your personal information. You may, however, choose to contact MDP by email, in which case we will collect your name, email address and any other information that you chose to provide to us. Please do not provide personal information that you do not want us to have.

In addition, MDP may gather information about you automatically through your use of the Website, e.g., your IP address and how you navigate our Website. We may also collect information about you by using cookies and other technologies (collectively, “Tools”). We may use this information to better understand, customize and improve the user experience of our Website, services and offerings. For example, we may use web analytics services such as Google Analytics that leverage Tools to help us understand how visitors engage with and navigate our Website. Information on how Google Analytics collects and processes your data is available here: www.google.com/policies/privacy/partners/.

Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, including how to see what cookies have been set and how to manage or delete them, you may visit www.allaboutcookies.org.

How We Use the Information We Collect

If you choose to provide information to MDP, for example by email, the information is used for the purpose you provided it to us. For example, if you provide your contact information in an inquiry to MDP, we will use your contact information to process and respond to that inquiry and any related activity that may result from your inquiry.

How We Share the Information We Collect

Currently, MDP does not collect any personal information through the Website. If this changes in the future, we may (without your consent) share your personal information with MDP’s affiliates for the purposes described in this Policy.

MDP may disclose personal information about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Links to Third-Party Websites

The Website may contain links to other web sites. MDP has no control over and is not responsible for the privacy policies or practices of such sites. Whenever you link to another website, you may be asked to provide registration or other information. Please note that any information that you provide is going to a third party, and therefore you should familiarize yourself with that party’s privacy policies.

Data Transfers

The Website is controlled and operated from the United States and is not intended to be subject to the laws or jurisdiction of any country or territory other than that of the United States.

Information Security

MDP maintains appropriate technical and organizational measures designed to protect your personal information against loss or accidental, unlawful or unauthorized, alteration, access, disclosure or use. Unfortunately, no data transmission or storage system can be guaranteed to be completely secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they don’t track the user. MDP does not currently change its practices, described elsewhere in this Privacy Policy, in response to DNT browser settings or signals. For information about DNT, you may visit www.allaboutdnt.org.

Third parties may collect personal information about your online activities over time and across different websites, including your use of this Website. This Privacy Policy does not apply to, and we are not responsible for, the practices of third parties that collect your personal information.

How long we keep information

If MDP collects personal information through the Website, the time period for which we keep personal information depends on the purposes for which we collected it. In all cases we keep it for as long as necessary to fulfill those purposes. We will then delete this personal information unless we are required to preserve it in connection with litigation, investigations and proceedings, or if a longer retention period is required or permitted by applicable law.

Governing Law

This Privacy Policy forms part of our Terms of Use (available at https://www.mdcp.com/terms-of-use) and as such shall be governed by and construed in accordance with the laws of the State of Illinois, as further provided in the Terms of Use.

Information for EEA and Cayman Islands

Madison Dearborn Partners, LLC is the data controller in respect of any personal information that may be collected through the Website.

If we collect your personal information, we process your personal information for the purposes described above on the basis that it is necessary for our legitimate interests in operating, managing and improving the Website.

When transferring personal information from within the EEA or the Cayman Islands to countries outside the EEA or the Cayman Islands, we comply with European Union law by using Standard Contractual Clauses approved by the European Commission or by adopting other means to ensure that adequate safeguards are applied (including, where relevant, transfers to a recipient with an appropriate Privacy Shield certification or appropriate arrangements in compliance with obligations in the Cayman Islands). If you would like more information on how we comply with transfer requirements please contact legal@mdcp.com.

If you are located in the EEA or the Cayman Islands or if you provide information in relation to one of our Cayman Islands funds, subject to applicable law, you may have the following rights in relation to personal information that we hold about you:

  • To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
  • To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
  • To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
  • To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal information;
  • Where you have given us consent to process your personal information, to withdraw your consent;
  • To request that we provide a copy of your personal information to you in a structured, commonly used and machine-readable format in certain circumstances; and
  • To object to certain of our data processing, such as for direct marketing purposes.

If MDP’s processing of your personal data is subject to these laws and you wish to exercise any of your data protection rights or if you consider that we have processed your personal information in violation of applicable law, please contact us as detailed in the “How to Contact MDP About Privacy Matters” section below.

If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

How to Contact MDP About Privacy Matters

If you would like to contact MDP for any reason concerning our privacy practices, please email us at legal@mdcp.com

Updates to this Privacy Policy

MDP may change or update portions of this Privacy Policy at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to the Privacy Policy. The revision date appearing on the first page of this Privacy Policy underneath the title will identify the date of the last update or revision.

Exceptions to this Privacy Policy

This Privacy Policy applies only to the public sections of the Website. If you are permitted access to private areas, the terms of your subscription agreement will control our use of provided information.

CALIFORNIA CONSUMER PRIVACY STATEMENT

Effective: January 1, 2020

This Statement does not apply to (i) MDP personnel or job applicants seeking opportunities at MDP, (ii) personnel working on behalf of business partners with whom we are conducting business, or (iii) information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act (and its implementing regulations) or the California Financial Information Privacy Act.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

  1. Notice of Collection and Use of Personal Information

Categories

We may collect the following categories of personal information about you online or offline:

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags; unique pseudonym or user alias; telephone number), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers

Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information

Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status

Commercial Information: commercial or investment information, including records of personal property, financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies

Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

Sensory Information: audio, electronic, visual, and similar information

Employment Information: professional or employment-related information

Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Purposes

We may use the categories of personal information listed above for the purposes described in the MDP Website Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described below:

  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, auditing compliance

  • Short-term, transient use

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

  • Debugging to identify and repair errors that impair existing intended functionality

  • Undertaking internal research for technological development and demonstration

  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

  1. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection

  • From you, for example, through your use of our websites, when you send us an email, visit our facilities, or otherwise contact or communicate with us

  • From monitoring tools, such as cookies that track your use of our websites and security cameras in certain of our facilities

  • Our affiliates

  • Our portfolio companies

  • Businesses that we are evaluating in connection with a potential investment or business opportunity

  • Vendors (e.g., background check providers), advisors and other business partners

  • Recruiting agencies, social media networks or publicly available sources

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties

  • Our affiliates

  • Vendors, broker-dealers, advisors and others who provide services to us or on our behalf

  • Professional services organizations, such as auditors and law firms

  • Prospective lenders to or creditors of a fund or portfolio company in which we have or are considering investing

  • Our portfolio companies

  • Government entities, including regulatory agencies and law enforcement

We have not sold personal information during the 12-month period prior to the effective date of this California Consumer Privacy Statement.

c. Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties for a business purpose all of the categories of personal information about you listed in Section 1 above.

  1. California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access or deletion request, email us at legal@mdcp.com or call us at 312-895-1000.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: address, date of birth, unique personal identifier, nationality, telephone number, email address, CV information or details of a transaction. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact legal@mdcp.com or 312-895-1000 from 8:30AM-5:30PM Central Time to request this Statement in an alternative format.