WEBSITE PRIVACY NOTICE

Last updated November 2024

Your privacy is important to Warren Equity Partners Manager, L.P. and its affiliates (“our”, “us”, “we” or “WEP”). To better protect your privacy, we are providing information explaining the manner in which WEP processes your personal information and the measures that WEP takes to preserve the privacy and security of your personal information.

This Website Privacy Notice, together with the California Website Privacy Notice Supplement and the EEA-UK Website Privacy Notice Supplement (the “Privacy Notice”), describes how we gather and use information in connection with https://www.warrenequity.com (the “website”) and your communication with us in relation to the website. We gather limited types of personal information through the website, and the types of personal information we collect about you depends on the nature of your interaction with us. If you provide personal information through other means (e.g., as an employee or seeking employment, or as a client or investor in other contexts), you will receive a separate privacy notice in each such context which will govern our processing of such personal information.

If you are a California resident, please also see the California Website Privacy Notice Supplement.

If you are located in the European Economic Area, the European Union, or the United Kingdom, or your personal data is otherwise subject to EU and/or UK data protection laws, please also see the EEA-UK Website Privacy Notice Supplement.

What information do we collect about you?

We may collect the following categories of information from you in connection to our website:

  • identifiers, such as Internet Protocol address, as well as any email addresses, names or other identifiers;
  • internet or other electronic network activity information, such as information regarding use of our website (e.g., cookies, browsing history and/or search history); and
  • any other personal information that you may provide us during the course of your interaction with our website, including by contacting us at [email protected].

How do we obtain your personal information?

In connection with operating our website, we collect and maintain your personal information from the following sources:

  • information from your communications with us in connection with our website; and
  • information captured on our website, including any information captured via cookies (or similar technology).

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

How do we use your personal information?

We may use any personal information provided to us through or in connection with our website, for one of the following business or commercial purposes:

Purpose Legal Basis (relevant to the EEA-UK Website Privacy Notice Supplement)
To perform services for you. Contractual necessity; and/or our legitimate interest in operating our business.
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. Our legitimate interest in operating our business.
To provide you with support and to communicate with you, including responding to requests for information submitted by you through our website. Our legitimate interest in operating our business.
To provide advertising and marketing services. Our legitimate interest in operating our business.
To keep a record of your relationship with us. Our legitimate interest in operating our business.
Ongoing operations, administrative, reporting and other processes. Legal requirement; contractual necessity; and/or our legitimate interest in operating our business.
To audit and verify the quality and effectiveness of our services and compliance. Our legitimate interest in operating our business.
To maintain the safety, security and integrity of our websites, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity. Our legitimate interest in operating our business.
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 government regulations. Legal requirement.
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 the website users is among the assets transferred. Our legitimate interest in operating our business.
For any other purpose that has been notified in writing. Consent or as notified.

We may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information.

Marketing Communications

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.

Who do we share your personal information with?

Your personal information may be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this Privacy Notice. We use a number of service providers that provide a wide range of services including legal and financial professional advisors, our auditors, recruitment firms, consultants, IT and data security providers, data hosting providers and in some instances, placements agents, administration agents, depositories, investment managers and other fund administrators. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.

We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.

Security and Retention of Personal Information

WEP maintains operational policies and physical, electronic and procedural protections to safeguard and secure its data networks in order to prevent unauthorized access to personal information. However, the transmission of information and data via the Internet is not completely secure, and although we make an effort to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through our website. Any transmission of personal information or data by you to or through this website is at your sole risk.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes.

Notification of Changes

We reserve the right to amend this Privacy Notice from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Notice. Accordingly, users are strongly encouraged to review this Privacy Notice regularly. If we decide to change what information we collect, how we use it and under what circumstances, if any, we disclose it, we will update this Privacy Notice. If at any point we decide to collect personal information through this website or use any collected information from this website in a manner different from that stated at the time it was collected, we will notify users by making updated information available on this page.

Capacity

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

Cookies

Information regarding how you access the website (e.g., browser type, access times, and Internet Protocol (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 our 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 our website. 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.

Cookie Name Type/Purpose
wfwaf-authcookie Used by Wordfence to check whether the user is logged in
wordpress_logged_in Used by WordPress to check which user is logged in
wordpress_sec Used by WordPress to record the user’s session
wp-settings Used by WordPress to customize the user’s interface
wp-settings-time Used by WordPress to check the user’s local time
wpe-auth Used by WPEngine for authentication purposes
AEC Used by Google to detect spam, fraud, and abuse
APISID Used by Google to personalize ads
DV Used by Google to personalize ads
HSID Used by Google to detect spam, fraud, and abuse
NID Used by Google to serve personalized ads to logged-out users
OGP Used by Google to provide Google Maps functionality
OGPC Used by Google to provide Google Maps functionality
OTZ Used by Google analytics to collect website usage statistics
SAPISID Used by Google to personalize ads
SEARCH_SAMESITE Used by Google to keep track of the correct website domain
SID Used by Google to detect spam, fraud, and abuse
SIDCC Used by Google to detect spam, fraud, and abuse
SSID Used by Google to personalize ads
__Secure-1PAPISID Used by Google to personalize ads
__Secure-1PSID Used by Google to personalize ads
__Secure-1PSIDCC Used by Google to personalize ads
__Secure-1PSIDTS Used by Google to personalize ads
__Secure-3PAPISID Used by Google to personalize ads
__Secure-3PSID Used by Google to personalize ads
__Secure-3PSIDCC Used by Google to personalize ads
__Secure-3PSIDTS Used by Google to personalize ads

CALIFORNIA WEBSITE PRIVACY NOTICE SUPPLEMENT

This California Website Privacy Notice supplements the general Website Privacy Notice set forth above 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 supplement 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 general Website Privacy Notice set forth above.

What does this California Website Privacy Notice apply to?

This California Website Privacy Notice applies to California residents and solely with respect to your interactions with WEP through our website, as described above in the general Website Privacy Notice.

What information do we collect about you?

We collect limited types of personal information through our website, as further set forth in “What information do we collect about you?” section in the general Website Privacy Notice above.

How do we obtain your personal information?

In connection with forming and operating our website, we collect and maintain your non-public personal information from the sources listed in “How do we obtain your personal information?” section in the general Website Privacy Notice above.

How do we use your personal information?

There is a need to process personal information for the purposes set out in “How do we use your personal information?” section in the general Website Privacy Notice above.

Who do we share your personal information with?

We share personal information with third parties in connection with the forming and operating of our website and the purposes set out in this Privacy Notice, as described in “Who do we share your personal information with?” section in the general Website Privacy Notice above.

How do we keep your personal information secure?

We take measures to ensure the security of your personal information as described in “How do we keep your personal information secure?” section in the general Website Privacy Notice above.

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 certain 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 and use of personal information specific to you over the last twelve (12) months. Such information includes:

  • the categories of personal information we collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting such personal information;
  • the categories of third parties with whom we share the personal information;
  • the specific pieces of personal information we have collected about you; and
  • whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: 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, please submit or have your authorized representative submit a request using any of the methods set forth below:

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 further information or your investor portal access credentials, if applicable, in order 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 using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact [email protected] with any questions about this California Website Privacy Policy.

EEA-UK WEBSITE PRIVACY NOTICE SUPPLEMENT

This European Economic Area (“EEA”) and United Kingdom (“UK”) Website Privacy Notice Supplement (“EEA-UK Website Privacy Notice Supplement”) supplements the general Privacy Notice set forth above with respect to our use of personal data which is subject to EEA-UK Data Protection Laws.

For the purposes of this EEA-UK Website Privacy Notice Supplement, “EEA-UK Data Protection Laws” mean all applicable laws and regulations relating to privacy, protection or processing of personal data in the EEA, European Union (“EU”) and UK, including the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union Withdrawal Act 2018 (“UK GDPR”), and including in respect of the foregoing any implementing or successor legislation and any amendments or re-enactments. The terms “controller”, “data subject”, “personal data”, “processor”, “process” and “processing” shall be interpreted in accordance with the applicable EEA-UK Data Protection Laws.

Information required to be disclosed under EEA-UK Data Protection Laws regarding the collection of your personal data that is not set forth in this EEA-UK Website Privacy Notice Supplement is otherwise set forth in the general Website Privacy Notice. To the extent there is any conflict in respect of any processing subject to EEA-UK Data Protection Laws between the general Website Privacy Notice and this EEA-UK Website Privacy Notice Supplement, this EEA-UK Website Privacy Notice Supplement shall apply. Please read this EEA-UK Website Privacy Notice Supplement carefully.

To the extent that EEA-UK Data Protection Laws apply to our processing of your personal data, we will be a “controller” of your personal data. In simple terms, when applicable, this means we: (i) “control” the personal data that we collect from you or other sources; and (ii) make certain decisions on how to use and protect such personal data.

What categories of personal data do we collect?

We collect limited categories of personal data through our website, as further set forth in “What information do we collect about you?” section in the general Website Privacy Notice above.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or any information about criminal convictions and offences.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data.

How do we obtain your personal data?

In connection with forming and operating our website, we collect and process your personal data from you and other third parties and/or publicly available sources listed in “How do we obtain your personal information?” section in the general Website Privacy Notice above.

How do we use your personal data?

There is a need to process personal data for the purposes and on the legal bases set out in the “How do we use your personal data?” section in the general Website Privacy Notice above.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Failure to provide personal data may mean that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

No automated decision-making, including profiling, is used when processing your personal data.

Disclosure and transfer of personal data

To the extent your personal data is transferred to a Non-Equivalent Country (as defined below), such transfers will only be made in accordance with EEA-UK Data Protection Laws. For the purposes of this EEA-UK Website Privacy Notice Supplement, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK (as applicable) in accordance with the applicable EEA-UK Data Protection Laws to ensure an adequate level of protection for personal data.

Security and retention of personal data

We take measures to ensure the security of your personal data as described in “How do we keep your personal information secure?” section in the general Website Privacy Notice above.

Your rights

To the extent that the EEA-UK Data Protection Laws apply to our processing of your personal data in connection with our website, you may have the following rights:

  • Access: You may have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
  • Correction: You may have the right to notify us of changes to your personal data if it is inaccurate or needs to be updated.
  • Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible due to legal and regulatory obligations.
  • Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data override your own rights.
  • Object: You may have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
  • Portability: If you wish to transfer your personal data to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
  • Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

These rights are not absolute and in certain circumstances their exercise may not be possible including when personal data must be maintained to comply with applicable laws.

To exercise these rights and controls, please contact [email protected]. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response

Contact Us

If you have any questions or concerns about this EEA-UK Website Privacy Notice Supplement, please contact [email protected].

Complaints

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.

Back to all posts