Privacy Notice

Last Updated and Effective Date: May 1, 2024

FALFURRIAS MANAGEMENT PARTNERS, LP
FALFURRIAS CAPITAL PARTNERS II, LP
FALFURRIAS CAPITAL PARTNERS III, LP
FALFURRIAS CAPITAL PARTNERS IV, LP
FALFURRIAS CAPITAL PARTNERS V, LP
FALFURRIAS GROWTH PARTNERS I, LP

This Privacy Policy applies to Falfurrias Management Partners, LP; Falfurrias Capital Partners II, LP; Falfurrias Capital Partners III, LP; Falfurrias Capital Partners IV, LP; Falfurrias Capital Partners V, LP; and Falfurrias Growth Partners I, LP (“we,” or “us”). This Privacy Policy describes how we collect, use, disclose, and process the Personal Information of visitors (“you” and “your”). We reserve the right to change this Privacy Policy at any time. If we change our Privacy Policy, we will post an updated version on this website. Please check back periodically to see if our Privacy Policy has been updated. Updates to the Privacy Policy will be referenced by the “Last Updated and Effective Date” date shown above.

1. Definitions

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person or household. “Personal Information” does not include: (a) publicly available information or lawfully obtained, truthful information that is a matter of public concern; or (b) information that is deidentified or aggregate information.

2. Information We Collect, the Categories of Source of Collection and the Purpose for Collection

Set forth below are the categories of Personal Information we collect and that have collected in the preceding 12 months, the categories of sources from which the Personal Information was collected and the business or commercial purpose for such collection. In some instances, you may be able to choose what information to provide, but sometimes we require certain information from you to use certain features of our website. Please note that we may not collect all of the information referenced below regarding you and we may not use your Personal Information for all purposes set forth in this Privacy Policy.

^* We collect personal information you provide directly to us, including when you: (i) subscribe to our email communications/newsletter; (ii) contact us via phone, email, or postal mail; or (c) connect with us via social media.

^** In addition to information you provide directly to us, we as well as our service providers, may automatically collect some personal information about you, including when you: (i) browse our website; (ii) download materials from our website; (iii) open an email or click on a link contained in our emails; (iv) view our social media profiles and sites; or (v) post or share information about us. See the section entitled Cookies below for additional information.

We may aggregate and/or de-identify your personal information so that it can no longer be linked to you. We may use and share aggregated/de-identified information for any purpose.

We do not use or disclose sensitive Personal Information.

3. Cookies and Tracking Technologies

We and our service providers use cookies and other tracking technologies (such as web beacons, tracking pixels, and HTTP referrers) to collect and store information about your interactions with our website, including information about your browsing and purchasing behavior. Cookies are small files that are transferred to a computer’s hard drive through a web browser that enable a website’s or service provider’s systems to recognize the user’s browser and capture and remember certain information. In general, we and our service providers use cookies and other tracking technologies to optimize the functionality of our website (including by storing your browsing preferences for future visits and identifying repeat visitors), to help us understand how users interact with our website, and to provide users with content or advertising based on their browsing activities.

If you do not want to have cookies placed on your device, you should set your browser to refuse cookies before accessing our website. Please review your browser’s Help menu for instructions, or visit www.allaboutcookies.org for more information on disabling and deleting cookies. Please note that, if you turn cookies off, some features of our website may not function properly.

Emails that we and our marketing service providers send may include tracking tools that provide us with information related to whether you’ve opened an email or clicked on a link contained in an email. More information on how to unsubscribe from our marketing emails is found below.

4. Personal Information We Disclose

We do not sell your Personal Information and we do not share your Personal Information for cross-context behavioral advertising (targeted advertising).

We disclose and have disclosed in the preceding 12 months certain of Personal Identifiers (such as name, email address, and organization/company name) to DealCloud, which is our Client Relationship Management application. We may also disclose your Personal Information to our insurers and professional advisers for the purposes of managing risks, obtaining professional advice, exercising or defending against legal claims. We may also disclose your Personal Information to operate our website, run analytics, improve our services, and for the purpose of marketing our services to you. All of these parties provide services on our behalf and that is the business purpose for the disclosures of the Personal Information to them.

We may also disclose Personal Information, as necessary: (a) to comply with any legal process; (b) to respond to requests from public and government authorities; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use Personal Information in connection with or during negotiation of any reorganization, acquisition, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

Finally, we may in the future disclose your Personal Information to certain parties to run our business, including to our affiliates, subsidiaries, portfolio companies and their advisors, as well as our fund partners and partners of successor funds and alternative fund vehicles in connection with closing documentation, partner reports, financial statements or other partner communications.

5. Our Retention Policy – How Long We Keep Your Personal Information

We will retain each category of your Personal Information identified above for an amount of time that is reasonably necessary for us to use the information for the purposes disclosed herein and for any other permitted purposes, including retention of Personal Information pursuant to any applicable contract, law or regulation. To determine the appropriate retention period for Personal Information, we 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 process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

6. Data Security

We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the Personal Information we collect, use, process and disclose. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Information. We evaluate these measures on a regular basis to help ensure the security of the processing. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

7. Email Communications

You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in every commercial email we send, or by sending us a request to unsubscribe at falfurrias@falfurrias.com. If you opt-out of receiving marketing email communications, we may still send you email messages related to specific transactions with us. Unsubscribing yourself from our marketing communications will not affect our service to you.

8. Children

Our website is not intended for children nor targeted to children under the age of eighteen (18). We do not knowingly collect personal information from children under the age of 18. If we learn that we possess information from a child under the age of 18, we will delete such information in accordance with the Children’s Online Privacy Protection Act or other applicable laws. If you are a parent or guardian and you believe that your child under the age of 18 has provided us with personal information without your consent, please contact us. Our contact information is below.

9. Your Rights if You Are a Resident of California

California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2023, and related regulations. Your right to submit certain requests as a California resident are described below. Please note that these rights are subject to certain exceptions and certain of these rights are subject to verification mechanisms.

• Right to Know Personal Information Collected About You. You have the right to know: (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting your Personal Information; and (4) the specific pieces of Personal Information we have collected about you. You may submit a request by calling us at 844-455-1005 or emailing us at falfurrias@falfurrias.com.
• Right to Know Personal Information Disclosed. You have the right to request that we disclose to you: (1) the categories of Personal Information that we collected about you; and (2) the categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose. You may submit a request by calling us at 844-455-1005 or emailing us at falfurrias@falfurrias.com.
• Right to Request Deletion of Your Personal Information. You have the right to request that we delete your Personal Information, subject to a number of exceptions. Following receipt of a request, we will let you know what, if any, Personal Information we can delete from our records. If we cannot delete all of your Personal Information, we will let you know the reason. You may submit a request by calling us at 844-455-1005 or emailing us at falfurrias@falfurrias.com.
• Right to Correct Inaccurate Information. If you believe that any of the Personal Information we maintain about you is inaccurate, you have the right to submit a request for us to correct that information. Upon receipt of a request, we will use commercially reasonable efforts to correct the information as you direct. You may submit a request by calling us at 844-455-1005 or emailing us at falfurrias@falfurrias.com.
• Right to Opt-Out of the Sale and Sharing of Your Personal Information. As noted, we do not sell your Personal Information and we do not share it for cross-context behavioral advertising. As such this right does not apply.
• Right to Limit the Use of Your Sensitive Personal Information. We do not collect or use any sensitive Personal Information. As such this right does not apply.
• Right to Non-Discrimination for Exercising Your Rights. If you choose to exercise any of your rights, you have the right to not receive discriminatory treatment by us.

When you make a request to know, delete and/or correct, to help protect your privacy and maintain security, we will take steps to verify your identity. Our verification procedure may differ depending on whether you have an account with us or not and the request you are making. The following generally describes the verification processes we use:

• Password Protected Accounts. If you have a password-protected account with us, we may use existing authentication practices to verify your identity but will require re-authentication before disclosing, correcting or deleting data. If we suspect fraudulent or malicious activity relating to your account, we will require further verification (as described below) before complying with a request to know or delete.

• Verification for Non-Accountholders. If you do not have, or cannot access, a password-protected account with us, we will generally verify your identity as follows:
  • For requests to know categories of Personal Information, we will verify your identity to a reasonable degree of certainty by matching at least two data points provided by you with reliable data points maintained by us.
  • For requests to know specific pieces of Personal Information, we will verify your identity to a reasonably high degree of certainty by matching at least three data points provided by you with reliable data points maintained by us. We will also require a declaration, signed under penalty of perjury, that the person requesting the information is the person whose information is the subject of the request or that person’s authorized representative. We will maintain all signed declarations as part of our records.
  • For requests to correct or delete Personal Information, we will verify your identity to a reasonable degree or a reasonably high degree of certainty depending on the sensitivity of the Personal Information and the risk of harm posed by unauthorized deletion. We will act in good faith when determining the appropriate standard to apply.

If there is no reasonable method by which we can verify your identity, we will state so in response, including an explanation of why we have no reasonable method to verify your identity.

If you use an authorized agent to submit a request to know, delete or correct, we may require the authorized agent to provide proof that you gave the agent signed permission to submit the request. We may also require you to do either of the following: (a) verify your own identity directly with us; or (b) directly confirm with us that you provided the authorized agent permission to submit the request. This requirement does not apply if you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4121 to 4130.

There may be situations where we cannot grant your request. For example, if you ask us to delete personal information that we are obligated to keep to comply with applicable law we may not be able to fulfill some or all of your request. We may also decline to grant your request where our use of your personal information serves a legitimate purpose such as for security purposes. Your request may also be denied if it compromises the privacy of others, is overly repetitive or extremely burdensome to fulfill.

We will respond to requests to know, requests to delete and / or delete no later than 45 calendar days. If we cannot verify your request within 45 days, we may deny your request. If necessary, we may take up to an additional 45 days to respond to your request but in such an event will provide you a notice and an explanation of the reason that we will take more than 45 days to respond to your request.

10. Nevada Privacy Notice

Nevada law provides that Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, and online service activity. Our uses of your Personal Information are not sales under Nevada law, so no opt-out right applies.

11. Non U.S. Visitors

This website is not intended for or directed to anyone outside of the United States. If you are located outside of the United States, please be advised that any information you provide to us will be transferred to the United States and that by submitting information, you explicitly authorize its transfer.

12. Changes to Our Privacy Policy

We may change this Privacy Policy in our sole discretion at any time. It is your responsibility to review our Privacy Policy before using our website or otherwise submitting your Personal Information to us.

13. How to Contact Us

If you have any questions or concerns about our privacy policies and practices, please feel free to contact us by calling us at (844) 455-1620, emailing us at falfurrias@falfurrias.com or by mail at Falfurrias Management Partners, 100 North Tryon Street, Suite 4100, Charlotte, NC 28202.