WEBSTER PRIVACY POLICY

This Privacy Policy (“Policy”) describes the privacy practices of Webster Equity Partners, L.P, and its affiliates and subsidiaries (“Webster,” “we,” “us,” or “our”), detailing how we collect, use, and disclose personal information in connection with your use of our website (“Site”) and your interactions with us (collectively referred to as the “Services”). This Policy also outlines your rights with respect to that information. Webster is the controller of your personal information under this Policy, which means we are responsible for your personal information. 

Please note that this Policy does not apply to the fund management services we provide to our investors which is subject to a separate privacy notice provided at or before the point of collection.  

The Site includes links to other websites controlled by unaffiliated entities.  Please note that information you provide to these other entities is subject to those entities’ respective privacy policies, over which we have no control.

Categories and Sources of Personal Information We Collect

We collect the following categories of personal information about you:

  • Contact Information and communications, such as your first and last name, email and mailing addresses, phone number, job title or role, and any other information you choose to provide when you interact with us, including through the contact us tab on the Site, phone, email or post or social media, we may collect your name, contact information (such as phone numbers and email address).
  • Suppliers/Partners and Investor representatives, such as your name, company, job role, contact information and the content of your communications with us when you enter into a supplier/partnership agreement or relationship with us or are a representative of a supplier/partner, we may collect 
  •  Internet and electronic network activity, such as your IP address, device identifiers, the type of computer, operating system, and Internet browser that you use to access the Site, and your engagement behavior, such as buttons or links you click on the Site
  • Other information. We may collect other personal information which is not specifically listed here, but which we will use as described in this Policy or as otherwise disclosed at the time of collection.

These categories of personal information come from the following sources:

  • Information you provide to us directly, including via the contact us tab on the Site.
  • Information we receive from third parties (for example, your employer or affiliated Company).
  • Information automatically collected by cookies, web beacons, and other tracking technologies when you interact with the Site. For more information on how we use these technologies, please see our Cookie Policy.

How We Use Personal Information

We use personal information for the purposes described below or as otherwise described at the time of collection:

  • Provide our Services.  It is in our legitimate interests to use personal information to operate, maintain, and provide you and your affiliated company with our Services, including ensuring you can use our Site.
  • Communicate with you about our services. It is in our legitimate business interests to use personal information to respond to your requests, provide support, and communicate with you about our Services and the Site, including by sending announcements, updates, security alerts, and support and administrative messages.
  • Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services and the Site safe for our users, which includes: (i) understanding your needs and interests, and personalizing your experience with the Site and our communications; (ii) troubleshooting, testing and research and to keep the Site secure; and (iii) investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.
  • Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve our Services, the Site and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, improve or add features to our Services and the Site, and to promote our business. 
  • Supplier/Partner and Investor relationships. Where you are a supplier/partner or a representative of a supplier/partner or Investor, it is in our legitimate business interests to use your personal information to contact you and to manage our relationship with you and/or your company. If we have entered into a contract with you/your company, we will use your personal information as required for us to perform our contractual obligations under the relevant contract
  • Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to: (i) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (ii) audit our internal processes for compliance with legal and contractual requirements and internal policies; (iii) enforce any terms and conditions that govern our Services; (iv) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and (v)comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.
  • Cookies. We collect personal information about you through cookies. For non-necessary cookies, such as those used for site analytics, we rely on your consent. For necessary cookies, which are essential for providing and securing our Site, we rely on our legitimate interests. For more information on how we use these technologies, please see our Cookie Policy.

Categories of Entities To Whom We May Disclose Personal Information

We may disclose the above categories of personal information about you to the following parties:

  • Affiliates. We may share your personal information with our general partner affiliates.
  • Service providers. We may share your personal information with Companies and Individuals that provide services on our behalf and help us operate the Services or our business (such as, hosting, information technology, support, email delivery and website analytics services).
  • Professional advisors. We may share your personal information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
  • Authorities and others. We may share your personal information with law enforcement, regulatory authorities, government entities, and private parties as required by law or when we believe in good faith that such sharing is necessary or appropriate for the compliance and protection purposes described in the section above.
  • Business transferees. We may share your personal information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests (including, in connection with a bankruptcy or similar proceedings).
  • Your instruction or permission. We share your personal information with other relevant third parties, where you give us permission to do so in the course of your relationship with us from time to time.

Data Retention

We retain personal information only for as long as is necessary to fulfil the purposes described in this Policy, including to provide access to the Site and where we have a legitimate business need to do so, such as where the retention is required by law or regulatory obligations (e.g. tax, legal, or accounting purposes), to enforce and prevent violations of our terms and conditions, or to defend against legal claims.

To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, any permissions you give us with regards to your personal information, and the applicable legal and regulatory requirements. 

Cross-Border Data Transfer

We are located in the United States and Luxembourg,  and also have external partners and service providers based in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country. 

Where there are cross border transfers of your personal information we will ensure that relevant safeguards are in place to afford adequate protection for your personal information, and we will comply with applicable data protection laws, For example, in relation to European personal information,  we rely on an adequacy decision by the European Commission or the UK Government, or on pre-approved contractual protections for the transfer of your personal information. For more information about how we transfer personal information internationally, please contact us as provided in the Contact Us section below.

Security

We maintain physical, electronic, and procedural safeguards, such as permitting only authorized employees, who are trained in the proper handling of investor information, to have access to that information.  We also ensure that unaffiliated entities who have access to personal information about our investors agree to maintain appropriate standards of security and confidentiality that meet or exceed applicable law.  Despite these measures, the Internet, nor systems and databases connected to it, are 100% secure, and we cannot and do not guarantee the security of your information, particularly when transmitted over the Internet.

Your Rights and Choices

Personal information requests. Depending on your location and the nature of your interactions with our Services, you may have the following data subject rights in relation to your personal information: 

  • Access. Provide you with information about the processing of your personal information and give you access to a copy of the personal information that we have collected about you. 
  • Correction. Update or correct personal information that is inaccurate or out of date.
  • Deletion. Delete your personal information that we no longer need to provide the Services or for other lawful purposes.
  • Portability. Provide your personal information in a portable, machine-readable, readily usable format to you or a third party of your choice.
  • Objection to us processing your personal information where we rely on our legitimate business interest to do so (see above) or for any direct marketing purposes (e.g. to send you newsletters or promotional emails).
  • Additional rights, such as to request that we restrict our use of personal information, and where applicable, you may withdraw your consent to our processing of your personal information. This won’t affect anything we have used your personal information for before you withdraw your consent.
  • Opt out of the “sale” of your personal information. Please note that we do not sell your personal information.

You are entitled to exercise the rights described above free from discrimination. To make a request, please email us or write to us as provided in the Contact Us section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may submit a request to exercise your rights through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us

Depending on where you reside, you may submit a request to know or a request to delete your personal information through an authorized agent.  If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us.

In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the Contact Us section below, or by submitting a complaint to the data protection regulator where you live, work, or where you feel a violation has occurred.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide you with services you request, including on our Site, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with these requested services. We will tell you what information you must provide by designating it as required at the time of collection or through other appropriate means.

Children’s Information

This Site is not intended for children under the age of 16.  We do not knowingly collect personal information from any person under the age of 16.  If you believe we have collected personal information from a child who is under 16 years old, please let us know and we will delete it.

Changes to This Privacy Policy

Any changes we may make to this Policy will be posted on this page, unless otherwise required by applicable law.  Please check back to see any updates or modifications.

Contact Us

If you have questions about this Policy or need to access this Policy in a different format, please contact us at:

Email:              privacy@websterequitypartners.com 

Address:          1000 Winter Street Waltham, MA 02451

Telephone:      866-305-3200

Effective Date: October 28, 2024

UK Representative.  

Pursuant to Article 27 of the UK GDPR, Webster Equity Partners, L.P. has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR: 

– by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/

– by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom