If you are a California Resident (as defined below), please review the below section Additional Information for California Residents for additional disclosures and Notice at Collection and Use of Personal Information for a description of your rights under the California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”).
In the event that you have any questions or concerns about this Privacy Notice, if you object to our uses of your personal information, or if you wish to exercise your rights under applicable law, please contact us at email@example.com.
A. The Types of Information We Collect and How We Collect It
When you visit and browse the Sites or communicate with us, you may directly provide us with information, including personal information, and we will collect certain information automatically or through other sources. When we use the term “personal information”, we mean any information that can help us directly or indirectly identify you and as otherwise defined under applicable law.
1. Information You Provide to Us
In order to access certain services provided via the Sites or to request certain information from Apollo via the Sites, you may be required to provide certain personal information.
Depending on how you interact with us and which Site you are visiting, including if you are vendor that we interact with, we may collect the following categories of personal information from or about you:
- identifiers and similar information such as, name, address, date and place of birth, email address, telephone number, social security number or other unique identifier number, tax identification number, driver’s license number, passport and other national identity details, internet protocol (“IP”) address, username, password, online identifiers or other similar identifiers;
- certain financial information protected under federal or state laws, like a signature, bank account, or other financial information;
- personal details, including characteristics of protected classifications under certain federal or state laws, such as gender or marital status, or information that might be considered special category data or otherwise sensitive under applicable law, including, racial or ethnic origin;
- commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth;
- education information, including information that is not publicly available, and personally identifiable information as defined in the Family Educational Rights and Privacy Act;
- internet or other electronic network activity information, including certain technological information like interactions with our Site or use of certain online tools;
- audio (e.g., voicemail), electronic, visual or similar information;
- professional or employment-related information, including occupation, compensation, employer, title, certifications, professional license numbers; and
- inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information.
Please note that some of this information may be considered special category data or sensitive data under applicable law.
You may also be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Sites, which rely on such information (for example, you will not be able to register for e-mail updates if you do not provide us with an e-mail address, and if you choose not to provide a username and password, we will not be able to provide you with services available through an online account).
2. Information We Collect Automatically
We also collect information about you automatically, which may include personal information.
For example, when you visit the Sites, we collect your IP address, your browser type, your operating system, the pages you view on the Sites, the duration of your visit, the pages you view immediately before and after you access the Sites, and the search terms you enter on the Sites.
If you communicate with our employees and other staff members via email, telephone, or other electronic channels, our information technology systems record details of those communications, sometimes including their content, for compliance and record-keeping purposes.
3. Additional Information Collection Practices
We may collect personal information about you from other sources such as our service providers or other vendors that assist with our business. Additionally, some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.
We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third-parties.
We collect such information through the following technologies (collectively “cookies”):
- Cookies. Cookies are small data files stored on your browser or device. Cookies may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). Additionally, some cookies may be temporary and erase when you close your browser (“session cookies”), and others may remain for a set duration (“persistent cookies”).
- Log Files. Tools that track actions occurring on the site, and collect data including your IP address, browser type, location, Internet service provider, referring/exit pages, and date/time stamps.
- Web Beacons. These “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
We use different types of cookies that provide various services, including:
- Strictly Necessary Cookies. These cookies are required for the operation of our Site and include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
- Analytics/Performance Cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our Site when using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. For more information on our use of analytics providers, please review, Analytics Providers, below.
- Functional Cookies. These cookies are used to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by name and/or remember your preferences (for example, your choice of language or region).
- Advertising/Targeting Cookies. These cookies may be set by us, our service providers, and our advertising partners, and are used to deliver content we believe to be most relevant to you. These cookies can help to measure the effectiveness of a campaign.
You can control cookies in various ways, including:
- Internet Browser. You can also control cookies through most browsers by changing your cookie settings, which are typically found in the “options” or “preferences” menu of your browser.
- Third Party Tools. You can visit http://www.allaboutcookies.org/ where you will find comprehensive information on cookie management and blocking which pertains to a wide variety of browsers.
Please note that if you turn cookies off, you may not have access to many features that may improve your browsing, like the features mentioned above, and some of our services may not function properly.
C. Links to Other Websites
The Sites may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.
Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Sites). These links are provided to you for convenience purposes only, and you access them at your own risk.
D. How We Use the Information We Collect
How we use your personal information may vary depending on how you interact with us and which Site you are visiting. Generally, we use information we collect about you primarily to provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other investors, as permitted by applicable laws.
We may collect, use or process your personal information for the following business or commercial purposes, and the lawful bases for our processing include the following:
- respond to your requests for forms, literature, or information, on the basis that it is in our business interests to respond to your requests, and you have requested that we do this;
- manage and administer customer services, including but not limited to the administration of your customer account. In most cases we do this is to meet our contractual obligations to you. Where there is no such obligation, we have a business interest in keeping our records accurate and up to date, which will assist you when we provide our services;
- process transactions as necessary to meet our contractual obligations to you;
- provide you with the services you have requested. In many cases we will provide these services to comply with contractual obligations to you, but if these services are not governed by any contract, we will use your information in this way to meet our business interests in providing the best service possible;
- prepare investor disclosure materials. This is necessary to comply with our legal obligations, to meet our interests in managing our business effectively, and for informing you and our other investors about how we are meeting your expectations;
- improve the Sites and learn about how visitors use the Sites. This is necessary for us to improve the services we offer through the Sites, and benefits you as it helps us make the Sites more usable and appealing;
- maintain security and prevent or detect crime and fraud. In many cases we are required to do this by applicable laws, but will otherwise do so to meet our legitimate interests in maintaining security and preventing crime;
- internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This processing benefits investors by supporting our provision of services;
- with your consent (including explicit consent), as required under applicable law.
- comply with legal obligations; and
- protect our rights, your rights, and the rights of others, as this may be necessary to meet our own high standards of business practice, as well as establish, exercise or defend legal claims.
We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the Sites for research about the use of the Sites and how the Sites could be improved, from which your interactions with the Sites cannot be singled out.
E. How We Share the Information We Collect
1. In Connection with Third Party Offers
We may share information about you with third-parties when you engage in certain activities on the Sites that are sponsored by third-parties. For example, you may choose to purchase products or services offered by a third-party or elect to receive information or communications from a third-party. If you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third-parties in association with the offerings.
We may disclose this information to third-parties for the purposes and on the basis described above (see Section B), for example, to process your transactions and to respond to your requests for information or communications from third-parties.
2. Service Providers
Sometimes we engage companies that process information for us or act on our behalf in association with the operation of the Sites and our services. For example, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.
We may also disclose your information to service providers that provide products or services to us or to facilitate our business operations, including marketing, advertising and related services.
Except as otherwise disclosed in this Privacy Notice or as otherwise communicated to you, Apollo takes reasonable steps to require these companies to collect, store, and use information about you only on our behalf and in accordance with this Privacy Notice. We share personal information with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.
3. Analytics Providers
The services we use include, but may not be limited to: Google Analytics and Adobe, which may provide you with choices about how they collect and use information. As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business. To find out more about how Google Analytics collects and processes data, please click here. Google Analytics has its own cookies that it uses to track and aggregate this information. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.
4. Additional Sharing Practices
We may share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above. We may also partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.
We may disclose information when we believe in good faith that such disclosures:
- are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request;
- will support our detection, prevention, or response to fraud or intellectual property infringement;
- at your direction or with your consent;
- will help protect your safety or security, including the safety and security of property that belongs to you; and
- will protect the safety and security of the Sites, databases, and/or third-parties, including the safety and security of tangible and/or intangible property that belongs to us or to third-parties.
We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.
The above-described disclosures are provided on the basis that they are either necessary to comply with our legal obligations or they are necessary to meet our legitimate interests in managing our business efficiently and for developing future business.
Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.
We do not sell your personal information and have not done so in the last 12 months from the effective date of this policy.
F. The Security Measures We Take to Safeguard Information
We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
G. Updating Your Contact Information
You may update your contact information and/or modify your communication preferences by sending us an e-mail at firstname.lastname@example.org. Additionally, we may provide tools on the Sites that facilitate such updates or modifications.
H. Children’s Information
The Sites are intended for use by those over 18, and minors under the age of 13 may not use the Sites.
We do not knowingly solicit or collect personal information on the Sites from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
I. Do Not Track
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.
Third-parties, such as our analytics providers, may collect data that relates to you on the Sites, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
J. Your Choices and Rights
If you no longer wish to receive marketing materials from us, you can let us know by clicking here or contacting us at email@example.com or using other unsubscribe features that we provide in our marketing communications.
Subject to local law, you may have certain additional rights regarding your personal information. These may include the following rights to: (i) access your personal information; (ii) rectify the information we hold about you; (iii) erase your personal information; (iv) restrict our use of your personal information; (v) object to the processing of your Personal Information in certain circumstances, including where we process Personal Information for direct marketing purposes or where we have processed such data on the basis of our legitimate interests; (vi) withdraw your consent to the processing of your Personal Information (where applicable); (vii) receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); and (viii) lodge a complaint with your local data protection authority, and withdraw any consent you have given to uses of your personal information.
If you are a California Resident please review Additional Information for California Residents below for a description of your California-specific rights regarding your Personal Information.
How to Exercise Your Rights
If you would like to discuss or exercise the rights you may have, contact us at firstname.lastname@example.org or call us toll-free at 833-271-8296. We will review your request and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.
We will process your request within the time provided by applicable law.
K. Shine the Light Disclosures
If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. If you wish to exercise this right, please email us at email@example.com. For additional information about your rights under the CCPA and how to exercise those rights, refer to Additional Information for California Residents.
L. Where Is Information Processed?
Our activities and the jurisdictions in which we are established are such that we process information collected via the Sites in and subject to the laws of the United States and other countries, which may not provide the same level of protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.
In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union or other applicable laws. However, we will seek to ensure that a similar degree of protection is afforded to your personal information by ensuring that, where possible, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements, or otherwise transfer personal information in accordance with applicable laws, such as, where the transfer is necessary for the performance of a contract between you and us or between us and a third party in your interest, where the transfer is necessary to establish, exercise or defend legal claims, or where the transfer is made for important reasons of public interest). For more information on the appropriate safeguards in place or to obtain a copy, please contact us at firstname.lastname@example.org.
M. How Long Is Information Retained?
We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.
When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.
N. Additional Information for California Residents
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, and which Site you are visiting, we may collect the categories of personal information listed above in The Types of Information We Collect and How We Collect It.
How We Use Collected Information
We also may use personal information from you for the business or commercial purposes described above in How We Use the Information We Collect.
For more information about our privacy practices, please review our entire Privacy Notice.
Our Collection, Use, Disclosure, and Sharing of Personal Information
What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information
In the preceding 12 months, depending on how you interact with us and which Site you are visiting, we may have collected the categories of personal information from the categories of sources listed above in the section, The Types of Information We Collect and How We Collect It. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section How We Use the Information We Collect.
Our Disclosure and Sharing of Personal Information
We do not sell your personal information. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information (described in more detail in The Types of Information We Collect and How We Collect It above) to the following categories of third parties, as describe in the below chart:
|Categories of Third Parties||Categories of Personal Information|
|Our affiliates||Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Professional or Employment Related Information; Inferences|
|Counterparties and intermediaries (e.g., broker-dealers)||Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Professional or Employment Related Information; Inferences|
|Third parties as needed to complete a transaction, including financial institutions or advisors, entities that assist with fraud prevention, custodians or lenders to or creditors of a fund||Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Professional or Employment Related Information; Inferences|
|Professional services organizations, such as auditors and law firms||Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Professional or Employment Related Information; Inferences|
|Prospective lenders to or creditors of a fund or portfolio company in which we have or are considering investing||Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Commercial information; Education information; Professional or Employment Related Information; Inferences|
|Our portfolio companies||Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Commercial information; Education information; Professional or Employment Related Information; Inferences|
In addition, in the preceding 12 months, we may have disclosed for a business purpose all of the categories of personal information identified in The Types of Information We Collect and How We Collect It above to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law.
We may also share your personal information with our service providers such as our IT and/or CRM providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in. or as otherwise permitted by, the CCPA.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected, and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not);and (v) request that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months (“Request to Know”).
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the GLBA. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
You may submit a Request to Know or Request to Delete, as described above, through the following toll-free telephone number 833-271-8296 or email us at email@example.com.
When you submit a Request to Know or Request to Delete may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification for a Request to Know or Request to Delete will be used for verification purposes only.
If you would like to use an authorized agent to submit a request, we may request proof that that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
O. Amendments to this Privacy Notice
We may change this Privacy Notice from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Notice to review any changes. Your continued use of the Sites after the effective date of any modification to the Privacy Notice will be deemed to be your agreement to the changed terms.
This Notice was last updated August 5, 2022.
P. How to Contact Us
This Privacy Notice is available in alternative formats upon request. If you have any questions regarding this policy or our privacy or data protection practices, or to request this Privacy Notice in an alternative format, please feel free to contact us at firstname.lastname@example.org.