Privacy Policy

Website Privacy Policy

 

Last updated: January 2024

_________________________

Our commitment to privacy: Your privacy is important to Orangewood Partners Management LLC and its affiliates (together, “Orangewood,” “our,” “us” or “we”). To better protect your privacy, we are providing information explaining our online information practices. This website privacy policy (this “Privacy Policy”) describes how we gather and use personal information and personal data that we collect:

  • On or through https://orangewoodpartners.com) and, as applicable, our other websites (including, as applicable, any of our online portals) (together, the “website”);
  • when you opt to receive communications from us;
  • about representatives of our vendors, business partners or portfolio companies;
  • to conduct business with you;
  • when you apply for a job with us; and
  • through other data collection points where we refer to this Privacy Policy.

Please read this Privacy Policy carefully. This Privacy Policy constitutes a legally binding agreement between Orangewood and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, this Privacy Policy, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree with any of the terms and conditions contained in this Privacy Policy, please do not access or otherwise use this website.

Visitors that are residents of California should also refer to our California Website Privacy Policy, which supplements this Privacy Policy, below.

Categories of Information we Collect and Process and How We Collect It

We collect and process various types of information from users of this website, including, but not limited to:

  1. Basic personal details and identifiers: such as name, email address, postal address, title, job title, and telephone number;
  2. Sensitive personal information: such as age, social security number, driver’s license number or other government-issued identification card information, passport number, national origin, residency (including tax residency), citizenship and visa status, marital status, and gender;
  3. Internet or other electronic network activity information: such as information regarding your use of our website and geolocation data. We obtain some information about your IP address and web browser that you use to access the website;
  4. Images: such as photographs taken at Orangewood events;
  5. Information received through communications with us: such as information provided through telephone calls and other verbal communications;
  6. Marketing and communications information collected about you or that you provide to us: your preferences in receiving marketing information from us and/or our third parties, and/or your communication preferences; and
  7. Other information: such as information obtained through publicly available external websites in certain circumstances.

Information You Provide to Us

Orangewood collects your personal information when you decide to interact with us (e.g., via any contact/communication feature we utilize on the website, when you visit our offices, when you communicate with us over email or the telephone, etc.).

We may also collect personal information about you, such as your IP address, through automated technology when you access and use our website, such as cookies and similar technology (please see the “Cookies” section below for information about how we use such technologies).

 

Information Provided by Third Parties or Publicly Available Sources

We collect personal information from third parties, such as a resumé sent to us by a recruiting firm, background information from a background check provider, personal information we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions.

If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal information (i.e., basic identifying and contact information, including your name, title, work email address, work postal address, job title and/or work telephone number, as appropriate) from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.

We process information in relation to companies that we are evaluating in connection with a corporate transaction or potential investment. This information may include your personal information including name, title, email address, postal address, job title, telephone number, passport or other government-issued identification, financial information and/or job and benefits information, as appropriate.

We do not knowingly collect personal information from children under the age of 16. If we are made aware that we have collected personal information from a child under the age of 16, we will delete it as soon as practicable.

If you log into the website, while we obtain your login credentials, your personal information is otherwise collected by the third party that operates the portal and is subject to that third party’s privacy notices.

Purposes for Collecting Personal Information

We may collect or disclose the personal information we collect about you for one or more of the following purposes:

Purpose Legal Basis to Process personal data
To conduct business with you or to provide you with the services or products you have requested, including responding to your enquiries and requests and providing you with support Contractual necessity; and/or our legitimate interest in operating our business and providing investment services
To keep a record of and manage your relationship with us Our legitimate interest in operating our business and providing investment services; and/or consent
To communicate with you, to operate, schedule and facilitate meetings and in relation to your participation in any of our events Our legitimate interest in operating our business and providing investment services; and/or consent
To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) and to conduct conflicts checks Our legitimate interest in operating our business and providing investment services; contractual necessity; legal requirement; and/or consent
To conduct due diligence and other business activities in connection with an actual or prospective corporate transaction or investment which we are party to Our legitimate interest in operating our business and providing investment services; contractual necessity; and/or legal requirement
To protect against, identify and prevent, fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website, assets our business, and other malicious or unlawful activity Our legitimate interest in operating our business and providing investment services; and/or legal requirement
To monitor and manage our portfolio companies Our legitimate interest in operating our business; and/or contractual necessity
Litigation management and conducting internal audits and investigations Our legitimate interest in operating our business; and/or legal requirement
To comply with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you Legal requirement; our legitimate interest in operating our business; and/or consent
To obtain advice from our professional advisors, including lawyers and accountants Our legitimate interest in operating our business
To administer and protect our business and our website Our legitimate interest in operating our business; and/or consent
To make suggestions and recommendations to you about goods or services that may be of interest to you Our legitimate interest in operating our business; and/or consent
For statistical analysis and market research, including to understand how our service may be improved for you (including through our use of cookies), and to improve our services Our legitimate interest in operating our business
For performance of our IT systems Our legitimate interest in operating our business
For any other purpose that has been notified, or has been agreed, in writing Consent

 

We monitor communications where the law requires us to do so. We also monitor communications, where required to do so, to comply with regulatory rules and practices and, where permitted to do so, to protect our respective businesses and the security of our respective systems.

 

Where required by applicable law, we will obtain your consent to send you marketing communications about our products, services, offers and promotions, and to invite you to events and to participate in surveys. You may request that we stop sending you marketing communications by emailing info@orangewoodpartners.com at any time.

Disclosure of Personal Information

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.

We may disclose any of the categories of personal information we obtain about you as described in the “Categories of Personal Information We Collect and Process and How We Collect It” section above amongst Orangewood and to service providers and persons employed and/or retained by Orangewood to fulfil the purposes set out in this Privacy Notice. We use a number of service providers to perform certain services including legal and financial professional advisors, auditors, recruitment firms, consultants, IT and data security providers, and data hosting providers.

We may also disclose personal information: (1) if we are required or permitted to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government or regulatory agencies, such as law enforcement, tax, and data protection supervisory authorities; (3) to establish, exercise or defend legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

 

We do not sell any of the personal information we collect about you to third parties. However, we reserve the right to transfer any personal information we have about you in the event of an actual or proposed sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation).

Retention of Personal Information

We retain your personal information for as long as reasonably necessary and proportionate to achieve the purposes and uses set out in this policy, as authorized by law, and to meet legal, taxation, accounting, risk management or business requirements. We may retain personal information for longer where required by our regulatory obligations, or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

How We Protect Your Information

We maintain physical, electronic, and procedural safeguards to prevent unauthorized access to data and to protect the integrity of our systems. We take reasonable steps to protect any personal information that you provide to us online by employing appropriate technical and organizational measures. We permit access only by authorized persons who need access to that information to provide services to us and you and who are required to abide by applicable confidentiality and information security practices. Despite the security procedures we employ, you should be aware that it is impossible to guarantee the security of information that you transmit to us via the internet.

Marketing

We may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we have provided to you, on the basis of our legitimate interest in operating our business. You may opt-in to certain kinds of marketing, or all forms of marketing, at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails, at any time.

 

Cookies

Information regarding how you access this website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website.

Subject to your consent, the website will place the cookies listed below:

 

Cookie Type Description Duration More Information
_ga_* Analytics A cookie to store and count page view. 1 year 1 month 4 days
_ga Analytics A cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors. 1 year 1 month 4 days
_gid Analytics A cookie to store information on how visitors use a website while also creating an analytics report of the website’s performance. Some of the collected data includes the number of visitors, their source, and the pages they visit anonymously. 1 day
_gat_gtag_UA_* Analytics A cookie to store a unique user ID. 1 minute

 

You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences. You may access any personally identifiable information we have about you by contacting us at info@orangewoodpartners.com.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

Further Information

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review this Privacy Policy regularly. If we decide to change this Privacy Policy, we will post those changes so our users are always aware of what personally identifiable information / personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of this Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy constitutes your acceptance of, and agreement to be bound by, such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you. The examples contained within this Privacy Notice are illustrations only and are not intended to be exhaustive. This Privacy Notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that apply to you.

The provisions in our Terms of Use are hereby incorporated by reference.

Contact Us

If you have questions about this Privacy Notice, wish to contact Orangewood, wish to exercise opt-out rights or submit verified requests, wish to appeal decisions, or wish to make any changes to the personal information you have provided to us, including removing it from a particular subscription list or removing it from our databases, or to access this Privacy Notice in an alternative format, please contact us at 212-324-5630 or info@orangewoodpartners.com.

 

Please note that, unless expressly advised otherwise, our website and communication facilities do not provide a means for completely secure and private communications and use. Although we will attempt to keep personal information confidential, from a technical standpoint, there is still a risk. For that reason, use caution when using the website, e-mail and other communication methods to communicate information to Orangewood that is considered to be confidential.

Our goal is to respond to any verifiable consumer request within the timeframes mandated by applicable law, and we will notify you in writing if we cannot meet any such timelines.

No Discrimination: We will not discriminate against you for exercising your rights under the applicable privacy regulations in your jurisdiction.

California Website Privacy Policy

This notice (the “California Website Privacy Policy”) supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Website Privacy Policy is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Privacy Policy. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102). 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.

What does this website privacy policy apply to? This California Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you? We collect limited types of personal information through our website, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depend on the nature of your interaction with us. We collect, or have collected within the last twelve (12) months, the following categories of personal information from individuals:

Category Examples Collected
A. Identifiers. First name, last name, email address, and organization. Yes, if you submit an inquiry via our “Contact Us” form on the Website
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). First name, last name, city, state or province, and country. Yes, if you submit an inquiry via our “Contact Us” form on the Website
C. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes

 

We do not knowingly collect or solicit personal information from anyone under the age of 18.

We do not collect or use sensitive personal information other than:

  • To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
  • As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions; As reasonably necessary and proportionate to ensure the physical safety of natural persons;
  • As reasonably necessary and proportionate to ensure the physical safety of natural persons;
  • For 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);
  • To perform services on behalf of our business;
  • To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

How do we obtain your personal information? In connection with forming and operating our Website, we may collect and maintain your nonpublic personal information from the following sources:

  • Information from your communications with us in connection with this Website, including any update notices provided by you.
  • Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

How do we use your personal information? We collect or disclose your personal information for one or more of the following business or commercial purposes (as such term is used in the CCPA):

  • To fulfill or meet the reason you provided the information.
  • To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
  • To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
  • To keep a record of your relationship with us.
  • Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
  • To audit and verify the quality and effectiveness of our services and compliance.
  • To maintain the safety, security, and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
  • As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • 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 Website users is among the assets transferred.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Orangewood retains the categories of personal information set forth above in the “WHAT INFORMATION DO WE COLLECT ABOUT YOU?” section of this California Website Privacy Policy only as long as is reasonably necessary for those business or commercial purposes set forth above, except as may be required under applicable law, court order or government regulations.

 

Who do we disclose your personal information to?

We do not sell or share for the purpose of cross-context behavioral advertising (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties. We have not in the last twelve (12) months, sold or shared any personal information collected to third parties.

We disclose, or, within the last twelve (12) months, have disclosed, personal information collected from you for a business or commercial purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category Category of Third-Party Recipients
A. Identifiers Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal law Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial information Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric information N/A
F. Internet or other similar network activity Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation data N/A
H. Sensory data N/A
I. Professional or employment-related information N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) N/A
K. Inferences drawn from other personal information N/A
L. Sensitive Personal Information Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

 

How do we keep your personal information secure? We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

Deletion rights: You have the right to request that we delete any of your 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.

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. 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;
  • the categories of third parties with 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 yes, 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 about you, 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, if that information is inaccurate. 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 this California Website Privacy Policy, 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: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information and our privacy policy and practices, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following number: 212-324-5630

Email us at the following email address: info@orangewoodpartners.com

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 request to verify your request. 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, and we may verify such authorized person’s identity. If Orangewood requests you verify your request and Orangewood does not receive your response, Orangewood will pause processing your request until such verification is received.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. But in certain cases, additional time might be required. Please contact us at the email address above with any questions about this California Website Privacy Policy.

 

Please contact us if you have interest in learning more about Orangewood Partners or how we can partner together.