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 (collectively, “MDP”, “we” or “our”). 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”.
When we use the term “personal information” in this Privacy Policy, we mean any information that identifies an individual person or reasonably relates to an identifiable individual, including online identifiers such as IP address and cookie identifiers.
In connection with investment activities, separate privacy notices are shared with investors as applicable.
We collect limited personal information in connection with your use of the Website, including information you voluntarily provide, and certain information collected automatically through your interaction with the Website. You may 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 gathers information about you automatically through your use of the Website, which may include information such as your IP address, device and browser information, pages visited and navigation patterns, and referring URLs. We also collect information about you by using cookies and other similar tracking 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 third-party analytics providers such as Google Analytics that leverage Tools to help us understand how visitors engage with and navigate our Website. These third-party providers may collect and process information about your interaction with the Website on our behalf. 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; however, disabling cookies may affect Website functionality. 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.
If you choose to provide personal 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.
We also use the information collected automatically through your interaction with the Website to operate and maintain the Website, analyze usage and performance, improve user experience, and detect and prevent security incidents.
We may disclose any of the categories of your personal information set out in the “Information We Collect” section above, under limited circumstances as described in this Policy, in each case, as permitted or required by law or regulation.
MDP may disclose personal information about you (a) to our affiliates for purposes consistent with this Privacy Policy, (b) to service providers (e.g., analytics providers, IT service providers, hosting providers) that process information on our behalf pursuant to contractual arrangements, (c) if we are required or permitted to do so by law, legal process or to regulatory authorities, for example due to a court order or a request from a law enforcement agency, (d) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (e) to detect, prevent, or respond to fraud, security incidents, or illegal activity, (f) 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).
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.
MDP maintains administrative, technical and physical safeguards which seek to protect your personal information against accidental, unlawful or unauthorized access, alteration, loss, disclosure or use. While we take reasonable steps to protect your information, 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 (“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 respond 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.
The time period for which we keep personal information that may be collected through the Website depends on the purposes for which we collected it. In all cases we retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy. 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. Retention periods vary depending on the nature of the information and applicable requirements.
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.
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, UK or the Cayman Islands to countries outside the EEA, UK or the Cayman Islands, we comply with applicable 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, by putting in place the UK International Data Transfer Addendum to the EU Commission Standard Contractual Clauses under S119A(1) of the Data Protection Act 2018 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, UK 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 information 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.
If you would like to contact MDP for any reason concerning our privacy practices, please email us at legal@mdcp.com.
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 “Last modified” date appearing on the first page of this Privacy Policy underneath the title will identify the date of the last update or revision.
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 or the applicable partnership agreement will control our use of provided information.
Effective: June 2026
This California Consumer Privacy Statement (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. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply. This Statement supplements this MDP Website Privacy Policy, with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended, and any implementing or successor legislation to the foregoing (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This Statement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. This Statement uses certain terms that have the meaning given to them in the CCPA.
Notice of Collection and Use of Personal Information
Categories
This section describes categories of personal information that may be collected across MDP’s operations, which may differ from the limited information collected through the Website. We collect or have collected within the last twelve (12) months some or all of the following categories of personal information about you online or offline:
Identifiers: identifiers such as a legal 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, state identification card number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: telephone number, signature, bank account number, credit card number, debit card number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and, for investors, verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets)
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, date of birth, birthplace, citizenship status, and military and veteran status
Commercial Information: account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s)
Online Activity: Internet and other electronic network activity information, including, but not limited to, use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries
Sensitive Personal Information: Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; and the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication.
We may collect information that is considered “sensitive” under the CCPA, such as account login information including username and password. When we do so, we use such information only for lawful purposes in compliance with the CCPA and other applicable privacy laws, such as to perform the services or provide the goods requested by you and to resist malicious, deceptive, fraudulent or illegal actions. We do not use such information to infer characteristics about individuals.
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 (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us)
•Maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
•Undertaking activities to comply with U.S., state, local, federal and non-U.S. laws, rules and regulations
•Making regulatory filings or registrations, giving notices to or responding to requests of applicable regulatory bodies or agencies, or seeking regulatory consents
• 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 to improve, upgrade, or enhance a service or device that is owned, manufactured, manufactured for, or controlled by us
•Collecting or processing sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer
•Any other purpose that has been notified, or has been agreed to, in writing
Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described 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 to whom we may have disclosed 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. Disclosure of Personal Information
We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties. In the preceding twelve (12) months, we have not sold or shared for the process of cross-contextual behavioral advertising any non-public personal information we collect about you to anyone, except as permitted or required by law or regulation.
We disclose, or within the last twelve (12) months have disclosed, certain personal information collected from you for a business or commercial purpose to the categories of third parties below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Categories of Third Parties
•Our affiliates
•Vendors, broker-dealers, advisors, placement agents 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
California Consumer Privacy Rights
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you over the last twelve (12) months. Such information includes:
•The categories of personal information we collected about you;
•The categories of sources from which the personal information is collected;
•Our business or commercial purpose for collecting such personal information;
•Categories of third parties to whom we disclose the personal information;
•The specific pieces of personal information we have collected about you; and
•Whether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: If you choose to exercise any of your rights under the CCPA, ask any questions about this Statement, or access this statement in an alternative format, please submit a request using any of the methods set forth below. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
• Email us at legal@mdcp.com
• If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at legal@MDCP.com, and we will call you between 9 a.m. and 6 p.m. Central Time.
Verifying Requests: We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), 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. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf. 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). If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Updates to this California Consumer Privacy Statement
MDP may change or update portions of this California Consumer Privacy Statement 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 California Consumer Privacy Statement. The effective date appearing on the first page of this California Consumer Privacy Statement underneath the title will identify the date of the last update or revision.