Terms of Use & Privacy
Effective October 11, 2022
B Capital Group Management, LP (“B Capital Group”, “us”, “our”, and “we”) is committed to respecting your privacy. This Privacy Policy describes how we collect, use, share and disclose personal data we collect on the websites owned and operated by B Capital Group (“Sites”) as well as through other means both online and offline. Users of our financial services should also refer to our investor privacy notice, which is supplied to you in the subscription materials at the time of your investment. Please note, we may use facilities outside of your home country to process, store or back up electronic information. If you have any questions about this policy or whether it applies to you, please contact us at privacy@bcapgroup.com.
The Sites may link to third-party websites or services not owned or controlled by B Capital Group. Please note that this Privacy Policy does not apply to those third-party websites and B Capital Group is not responsible for the data collection practices of any third parties.
BY PROVIDING YOUR PERSONAL DATA TO B CAPITAL GROUP OR OTHERWISE USING OUR SITE, YOU AGREE TO THE TERMS OF THIS POLICY AND OUR WEBSITE TERMS & CONDITIONS.
- The Information We Collect and Use
- Sharing Your Personal Data
- Sending Your Personal Data Internationally
- Retention and Deletion of Your Personal Data
- How We Protect Data
- Children’s Privacy
- Data Subject Rights
- California Disclosures
- Managing Your Communication Preferences Changes to This Policy
- Changes to this Policy
- How to Contact Us
The Information We Collect and Use
When we use the term “Personal Data” we mean information that can be used to identify you as an individual person.
What Categories of Personal Data We Collect
We collect the following categories of Personal Data:
- Identifiers: Identifiers such as your real name, postal and residential address, email address, account name, contact details, corporate contact information, and other similar identifiers.
- Protected Classifications: Information classified as personal or protected information by state, federal or other applicable law, including your nationality, date of birth, and gender.
- Sensory Information: Voice mail, audio, visual (including your photograph and signature)and similar information.
- Employment Information: Professional or employment-related information, includingyour employment and employer’s name.
- Education Information: Education information, including your level of education.
- Inferences: Inferences that we draw from your personal data in connection with a determination as to your suitability to make an investment, your capacity to evaluate the merits and risks of investments and your qualification to make an investment according to the terms of such investment.
How We Collect Your Personal Data
We collect Personal Data in various ways, including when you submit identifiable comments or other content to us on our Sites or when you otherwise contact us. We collect whatever information you supply and use this information to communicate with you if requested and to fulfill the purpose of the content submission. If you submit an application for employment with B Capital Group, we will collect information including your contact details, work history, employment needs and interests, and anything relevant to the job for which you are applying.
We may also obtain Personal Data on you from our portfolio companies, vendors (e.g., background check providers), data suppliers, including suppliers of certain resume-related information, advisors and other business partners, social media networks, or other publicly accessible directories and sources. These may include websites; bankruptcy registers; tax authorities; governmental agencies and departments and regulatory authorities to whom we have regulatory obligations; credit reference agencies; sanctions screening databases; and fraud prevention and detection agencies and organizations, including law enforcement.
Information Collected Automatically on Our Sites:
We use various technologies to collect data on our Sites. As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data. We and our service providers may also use cookies, scripts, and similar technologies to manage our websites and to collect information about you and your use of our Sites. These technologies help us to recognize you and customize or personalize your experience.
Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your Internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Sites. To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on.
Our website does not respond to Do Not Track Signals.
How We Use Your Personal Data
We collect, store and use your Personal Data for business or commercial purposes including the following:
Processing that is necessary for compliance with applicable legal or regulatory obligations, including without limitation:
- undertaking investor due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors (and, where applicable, their beneficial owners);
- sanctions screening and complying with applicable sanctions and embargo legislation;
- complying with requests from regulatory, governmental, tax, and law enforcement authorities;
- surveillance and investigation activities;
- carrying out audit checks, and instructing our auditors;
- maintaining statutory registers; and
- preventing and detecting fraud.
Pursuing our legitimate interests, or those of a third party to whom your Personal Data is disclosed, including without limitation:
- managing, operating, and growing our business and managing investor accounts, including through the use of third-party service providers;
- complying with a legal, tax, accounting, or regulatory obligation to which we or the third party are subject;
- assessing and processing requests you make;
- evaluating potential candidates for employment at B Capital Group and its affiliates or its portfolio companies;
- sending updates, information, and notices or otherwise corresponding with you;
- investigating any complaints, or pursuing or defending any claims, proceedings or disputes;
- providing you with, and informing you about, investment products and services;
- managing our risk and operations;
- complying with audit requirements;
- ensuring internal compliance with our policies and procedures;
- protecting against fraud, breach of confidence, or theft of proprietary materials;
- seeking professional advice, including legal advice;
- facilitating business asset transactions involving B Capital Group and its funds or related entities;
- monitoring communications to/from us (where permitted by law);
- creating, improving, and developing our Sites and other products and services; and
- protecting the security and integrity of our Sites and IT systems.
We will only process your Personal Data in pursuance of our legitimate interests where we have considered that the processing is necessary, proportionate and, on balance, our legitimate interests are not overridden by your legitimate interests, rights, or freedoms. Should we wish to use your Personal Data for any purpose that requires your consent, we will contact you to request it.
Sharing Your Personal Data
We do not sell any Personal Data to unaffiliated third parties or share it for purposes of cross-context behavioral advertising and have done so in the past twelve (12) months.
We may share your Personal Data with other entities within B Capital Group including with B Capital Group funds or related entities for any of the purposes set forth above. We may share your Personal Data with our agents and service providers. In certain circumstances, we may be legally obliged to share your Personal Data with relevant regulatory authorities such as the U.S. Securities and Exchange Commission. They, in turn, may exchange this information with foreign authorities, including tax authorities and other applicable regulatory authorities.
Our agents and service providers may process your Personal Data on our behalf, including with our banks, accountants, auditors, and lawyers, which may be data controllers in their own right. Our service providers are generally processors acting on our instructions. Additionally, a service provider may use your Personal Data where this is necessary for compliance with a legal obligation to which it is subject (for example, to comply with applicable anti-money laundering and counter-terrorist financing laws).
We may share your Personal Data with prospective creditors of B Capital Group and its funds or related entities or of a future or present portfolio company, with portfolio companies directly, or with a third party that acquires, or is interested in acquiring, all or a substantial part of our assets or equity interests, or that succeeds us in carrying on all or a part of our business. In certain circumstances, we may share your Personal Data in connection with the investigation and assertion of legal rights.
Sending Your Personal Data Internationally
The Personal Data that we collect from you may be transferred to and stored at, a destination outside your home country including the United States. Such third countries may not or may not be deemed to provide the same level of protection for Personal Data. When we do so and to the extent required by applicable data protection laws, we will rely on appropriate or suitable safeguards, including European Commission-approved Standard Contractual Clauses, or we ensure that applicable service providers receive your Personal Data in a country that is deemed to provide adequate protection to your data. You can request a copy of the Standard Contractual Clauses we may use by contacting us as set forth in the Contact Information section below.
We may further rely upon appropriate or suitable safeguards of your Personal Data for international transfer, including:
- obtaining your consent to transfer Personal Data after first informing you about the possible risks of such a transfer;
- when the transfer is necessary for the performance of a contract between you and B Capital Group, or if the transfer is necessary for the performance of a contract between B Capital Group and a third party, and the contract was entered into in your interest; and
- when the transfer is necessary to establish, exercise or defend legal claims.
Retention and Deletion of Your Personal Data
We will keep your Personal Data for as long as is consistent with the purposes for which we are processing it. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will retain some Personal Data after your relationship with us ends.
How We Protect Data
We apply technical, physical, and administrative information security measures designed to protect against unauthorized or unlawful processing of Personal Data, and against accidental loss or destruction of, or damage to, Personal Data, although we cannot guarantee that these will always be effective.
Children’s Privacy
Our services are not intended for children under the age of 18. We do not knowingly collect information from children under the age of 18, and we do not target children under the age of 18.
Data Subject Rights
Individuals in Australia, California and certain other US states, Canada, the Cayman Islands, Europe, Hong Kong, Israel, Japan, Singapore, South Korea, Switzerland, the United Kingdom, and certain other jurisdictions may have certain data subject rights. These rights vary but may include a right to:
- be informed about the purposes for which your Personal Data are processed;
- access your Personal Data, including requesting us to disclose to you the Personal Datawe have collected, used and disclosed about you during the past 12 months;
- stop direct marketing;
- restrict the processing of your Personal Data;
- have incomplete or inaccurate Personal Data corrected;
- ask us to stop processing your Personal Data;
- obtain a copy of your Personal Data in a portable format;
- opt out of the sale of Personal Data; and
- require us to delete your Personal Data in some limited circumstances.
Depending on your jurisdiction, you may also be entitled to direct any complaints in relation to our processing of Personal Data to your national or local data protection supervisory authority, or to the Cayman Islands Ombudsman, if the complaint is in relation to a Cayman Islands fund. Please consult local authorities.
The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Individuals who submit requests for access or erasure of Personal Data and certain other rights will be required to verify their identity by answering questions. For requests related to particularly sensitive information, we may require additional proof of identification. We will not disclose or delete any information until such an individual’s identity is verified. If you are making a request for access, we may not be able to provide specific pieces of Personal Data if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Data or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Data again before your request is submitted. In certain circumstances, we may not erase all Personal Data, as permitted by applicable law. We will process your request within the time provided by applicable law.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your signed permission to do so. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us and directly confirm with us that you provided the authorized agent permission to submit the request before we can honor the request. Agents who make requests on behalf of individuals will be required to verify the request by submitting signed authorization from the individual. We will not honor any requests from agents until authorization is verified.
California Disclosures
In the preceding 12 months, we have collected and used Personal Data in the manner described above in the sections “The Information We Collect and Use – What Categories of Personal Data We Collect; – How We Collect Your Personal Data; – How We Use Your Personal Data.” We may have disclosed to third parties for our business purposes all of the categories of Personal Data as described above in that section. We will not discriminate against you for exercising data subject rights.
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what Personal Data is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not share Personal Data with outside parties for their direct marketing.
Managing Your Communication Preferences
We want to communicate with you only if you want to hear from us. If you wish to opt-out of receiving any communications, you may do so at any time by contacting us using our contact information below.
Changes to this Policy
This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by posting the revised notice on the Sites and updating the effective date above.
How to Contact Us
If you have any questions or comments about this Privacy Policy or other privacy-related matters, please contact us at: privacy@bcapgroup.com.