Last Modified: June 2023
Visitors that are residents of the United Kingdom, the European Union or the European Economic Area should refer to our EU Privacy Notice supplement.
Our commitment to privacy
Your privacy is important to Nautic Partners, LLC and its affiliates (together, “Nautic,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
- in connection with your use of this website and its sub-pages (the “Site”), whether through a personal computer, mobile device, or otherwise;
- [through offline and online communications (including emails);
- when you opt to receive communications from Nautic;
- when you visit our offices;
- to conduct business with you;
- Located in the European Union (“EU”), European Economic Area (“EEA”) or the United Kingdom (“UK”), or if the processing of your PII would otherwise be subject to the GDPR, please also read our EU and UK Website Privacy Supplement.
- A resident of California, please also read our California Website Privacy Supplement.
What is PII?
PII is any information relating to an identified or identifiable individual, which may include (without limitation) first and last name, physical street address, email address, telephone number, Social Security number, payment card information, birth date, employment history, veteran status, certain health related data, passport information and photographs, or any other information that permits a specific individual to be contacted physically or online or otherwise personally identified. In general, PII does not include pseudonymized information, anonymized information, or aggregated information that does not allow a person in possession of such information to identify you individually.
What PII do we collect?
We may collect various types of information about you depending on the nature of our relationship or interactions with you. For example, we may collect some or all of the following PII:
- Basic information: name, gender, age, and/or date of birth.
- Contact information: email address, physical address and/or phone number.
- Information we obtain by automated means: the length of time spent on the Site, the pages accessed while visiting the Site and Internet Protocol (IP) addresses. In addition, when you use the Site a “cookie” may be placed on your device, as further described below.
- Information obtained through other communications with us: information provided by you through telephone calls, video communications, other verbal communications, and written correspondence.
- CV information: employment and education history, professional designations and other information relating to your qualifications.
- Images: video footage or static images recorded by our CCTV cameras at our offices and/or photographs of you that are taken at our events.
Why do we use your PII?
To the extent that you provide us with any PII, we may use such PII for the following purposes:
|Purpose||Legal Basis to Process PII under the GDPR|
|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 Site, 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 this Site||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|
|For performance of IT systems||Our legitimate interest in operating our business|
|For any other purpose that has been notified, or has been agreed, in writing||Consent|
Who do we share your PII with?
We will not disclose any PII about you to anyone, except as permitted or required by law or regulation, to service providers and as set out in the relevant Supplement.
- our group companies and affiliates;
- service providers, including those providing IT, web-design, HR, recruitment, and marketing services;
- placement agents; and
- data hosting providers.
We reserve the right to disclose your PII 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 PII to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
The Site is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to the Site who are under the age of 18 or knowingly collect PII from anyone under the age of 18.
Information regarding how you access the Site (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 data file placed on the hard drive of your computer) or other technologies or tools. This information is used to improve website performance and for our business purposes. This information allows us to customise the Site according to your individual interests and recognizes when you return to the Site, or may be stored by us for administrative purposes or to gather statistical data. Any information obtained for this purpose and collected by automated means may be disclosed to, or collected directly by, third party service providers. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of the Site, 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 the Site. 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.
Subject to your consent, our Site will place the following non-essential cookies:
|Cookie||Name||Type / Purpose||Duration / More Information / Expiration Date|
|.nautic.com/||_ga_*||To store and count page views||1 year 1 month 4 days|
|.nautic.com/||_ga||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 recognize unique visitors||1 year 1 month 4 days|
|.nautic.com/||_gid||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 (24 hrs)|
|.nautic.com/||_gat_gtag_UA_*||To store a unique user ID||1 minute|
|.nautic.com/||vv_session_id||To collect information about how visitors to our website navigate and interact with our site. This cookie collects information in an anonymous form, it does not record any personal data about you||Length of browsing session|
|.nautic.com/||vv_visitor_id||Used to collect information about how visitors to our website navigate and interact with our site. This cookie collects information in an anonymous form, it does not record any personal data about you||1 year 1 month 4 days|
If you have any questions about how we use any PII collected by the cookies placed by our Site, please contact Nautic’s Chief Compliance Officer at email@example.com.
We may send you direct marketing communications to keep you informed of relevant products and services. You may opt-in to receive our marketing communications by contacting the Chief Compliance Officer of Nautic at firstname.lastname@example.org.
You have the right to ask us not to not send you marketing messages by post, telephone or e-mail or any combination of these at any time. You can do this by clicking on the “opt-out”/unsubscribe link provided in our marketing emails, if applicable, or by contacting the Chief Compliance Officer of Nautic at email@example.com.
We are committed to protecting the PII you entrust to us. We implement security measures designed to protect any PII submitted by or collected from you from unauthorized access. We further protect your PII from potential security breaches by implementing certain technological security measures in accordance with generally accepted industry practices. In addition, we limit access to your PII to those employees, agents, contractors and other third parties who have a business need to know. They will only process your PII on our instructions and they are subject to a duty of confidentiality. However, these measures do not guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your PII we cannot guarantee the security of any information or data transmitted to or through this Site; any transmission of information or data by you to or through this Site is at your sole risk.
Notification of changes
Last Modified: June 2023
This California Website Privacy Supplement applies solely to your interactions with us through our Website (as defined below). If you provide PII to us 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 PII.
What information do we collect about you?
We collect limited types of PII through our Site and investor reporting portals,as well as through other electronic communications (e.g., emails), as applicable (collectively, our “Website”). The types of PII we collect about you depends on the nature of your interaction with us. The categories of PII we collect or have collected from individuals on our Website over the last twelve (12) months include the following:
|A. Identifiers||Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and drivers’ license or state identification card number).||YES|
|B. Additional data subject to Cal. Civ. Code § 1798.80||Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets).||YES|
|C. Protected classification characteristics under California or federal law||Date of birth, citizenship and birthplace.||YES|
|D. Commercial information||Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).||YES|
|E. Internet or other similar network activity||Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries||YES|
|F. Professional or employment-related information||Current or past job history or performance evaluations.||NO|
|G. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|H. Inferences drawn from other personal information||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
|I. Sensitive Personal Information||Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.||YES|
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;
- 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); and;
- To perform services on behalf of your business.
We do not knowingly collect or solicit PII from anyone under the age of 18.
How do we obtain your PII?
In connection with forming and operating our Website, we collect and maintain your non-public PII from the following sources:
- Information from your communications with us in connection with our 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 PII 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 PII?
Who do we share your PII with?
We do not sell or share (as such terms are defined in the CCPA) any of the PII we collect about you to third parties, nor have we done so in the past twelve (12) months.
We do not disclose any nonpublic PII about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including, but not limited to, administrators,lenders, banks, auditors, law firms, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants, third-party due diligence providers and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Within the last twelve (12) months, we have disclosed each of the categories of PII collected in connection with our Website with affiliates and service providers for a business or commercial purpose as set forth in the chart below.
|Personal Information Category||Category of Third-Party Recipients|
|A. Identifiers||Affiliates, professional service organizations, financial institutions|
|B. Additional data subject to Cal. Civ. Code § 1798.80||Affiliates, professional service organizations, financial institutions|
|C. Protected classification characteristics under California or federal law||None|
|D. Commercial information||Affiliates, professional service organizations, financial institutions|
|E. Internet or other similar network activity||None|
|F. Professional or employment-related information||Affiliates, professional service organizations, financial institutions|
|G. Non-public education information||None|
|H. Inferences drawn from other personal information||None|
We may also share your PII with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding or other disposition of all or a portion of our business, assets or shares.
How do we keep your PII 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 PII 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 PII 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 PII specific to you over the last twelve (12) months. Such information includes:
- the categories of PII we collected about you;
- the categories of sources from which the PII is collected;
- our business or commercial purpose for collecting such PII;
- the categories of third parties with whom we share the PII;
- the specific pieces of PII we have collected about you; and
- whether we disclosed your PII to a third party, and, if so, the categories of PII that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the PII 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.
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 using any of the methods set forth in the “Contact us” section, below.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your PII, please submit or have your authorized representative submit a request using any of the methods set forth below.
Submit a request online using the following online form: Contact Us.
Email us at the following email address: firstname.lastname@example.org.
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.
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. Please contact the Chief Compliance Officer of Nautic Partners, LLC at the email address above with any questions about this California Website Privacy Supplement.
Last Modified: June 2023
You do not need to take any action as a result of this EU and UK Website Privacy Supplement, but you do have certain rights as described below in the “Your rights under the GDPR” section, below.
What PII do we collect?
Why do we process your PII and what is our legal basis?
We will only use your PII 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 PII for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
If we require your PII 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 PII, and the possible consequences of you failing to provide this PII. Failure to provide this PII may mean that we cannot provide our services or products to you. In this case, we may have to cancel a service or product you have with us but we will notify you if this is the case at the time.
No solely automated decision-making, including profiling, is used when processing your PII.
How do we transfer your PII?
Your rights under the GDPR
You have the certain rights relating to the PII we hold about you as provided below, and there are a number of ways you can control the way in which, and what PII, we store and process about you. To exercise these rights and controls, please contact the Chief Compliance Officer of Nautic at email@example.com.
- Access: You have the right to ask for a copy of the PII 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 notify us of changes to your PII if it is inaccurate or it needs to be updated.
- Deletion: If you think that we should not be holding or processing your PII any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your PII (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 PII, override your own rights.
- Object: You 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 PII to another organization (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 PII 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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your PII (or to exercise any of your other rights). This is a security measure to ensure that PII is not disclosed to any person who has no right to receive it.
If you have any questions or concerns about this EU and UK Website Privacy Supplement, please contact the Chief Compliance Officer of Nautic at firstname.lastname@example.org.
Should you wish to lodge a complaint with regards to how your PII has been processed by us under:
- The UK GDPR, please contact the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.
- The EU GDPR, please contact your local supervisory authority in the EU Member State of your habitual residence, place of work, or place of the infringement concern or complaint.