Online Privacy Policy

ABOUT THIS POLICY

Integrum is an innovative, mission driven, and technology-centric investment firm that brings together proven leaders with a unique combination of investing acumen, strategic insights, thought leadership and global relationships to drive significant value for our stakeholders. Integrum’s headquarters is located at 55 Hudson Yards, 47 Floor, Suite A, New York, NY 10019.

Integrum takes privacy and the use of your data seriously and acknowledges the importance of protecting any personal information you may provide when you visit our website – such as your name, contact details or any other information from which you can be identified, either directly or indirectly (we refer to such information as “personal data”).

This Online Privacy Policy (this “Policy”) sets out how we will use any personal data collected by us when you visit this website and, more generally, which you provide to us or which we acquire through any day-to-day business with you as a consequence of visiting this website. This Policy is intended to provide information to individuals from whom we obtain personal data directly, as well as to those from whom we may acquire personal data indirectly (for example, if you provide us with another person’s contact details). This Policy is not directed towards our employees, officers or directors, or to investors, or prospective investors in us or in funds that we sponsor or manage. We address these relationships in separate policies relating to human resources and investor communications.

In this Policy, “Integrum” (or “we”, “our” or “us”) refers to Integrum Holdings LP. This Policy contains some provisions which are specific to certain data privacy laws, such as those in California and the European Economic Area.* For convenience we use the term “personal data” throughout this Policy, but visitors subject to California (or similar) privacy laws should be aware of differences in how this term can be used – in this regard, visitors are directed to the section below entitled California Residents.

Visitors are reminded that access to this website (the “Site”) is subject to our Terms of Use. This Policy concerns only the Site and does not concern any website to which the Site may link. Should you choose to follow any link to a third-party site, you should review the applicable privacy policy and terms of use to satisfy yourself that you understand and are comfortable with their practices concerning, among other things, your personal data.

Integrum reserves the right to amend this Policy at our discretion and at any time. Subject to any overriding legal requirement, amendments will not require any notice to you. However, any such amendment will not affect how we process personal data collected prior to such amendment taking effect. When we make changes to this Policy, we will post the updated Policy on the Site and update the Policy’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes. We urge you to review this Policy each time you visit the Site. If you do not agree with any provision of the Policy, you should not visit or use the Site. For revisions that significantly expand the ways we use or share the personal data we previously collected from you, we will display an alert on our Site or directly communicate with you in advance of and/or concurrently with the changes taking effect.

Based on the applicable laws of your country or state, you may have the right to request access to the personal data we collect from you, change that information, or delete it in some circumstances. If you have any questions or comments about this Policy, the ways in which we collect and use your information described below, your choices and rights regarding such use, or wish to exercise your rights, please do not hesitate to contact us at:

Phone: +1 (212) 970-2500

E-mail: contact@integrumholdings.com

Mailing Address:
Integrum Holdings LP
Attn: Chief Compliance Officer
55 Hudson Yards,
47 Floor, Suite A
New York, NY 10001

*This Policy complies with the California Consumer Privacy Act of 2018 (the “CCPA”). Supplemental provisions applicable to visitors, users and others who reside in California are described below in the section entitled CALIFORNIA RESIDENTS. Supplemental provisions for individuals in the European Economic Area and other countries (such as the United Kingdom) that have adopted laws substantially similar to the EU General Data Protection Regulation (“GDPR”) who may be entitled to receive information or exercise rights pursuant to the GDPR (or equivalent laws) are set out in the section entitled EUROPEAN ECONOMIC AREA AND UNITED KINGDOM.

COLLECTION AND USE OF PERSONAL DATA[1]

When you visit our Site, we may collect two different types of information about you: information you provide to us and information we collect through technology.

Personal data which you may provide to us and which we may collect includes your name, email address, contact information, professional pursuits and qualifications (for example, CVs, grades, and transcripts). Additionally, we may collect and retain a record of all communications with you, and we may monitor and record other activity on our Site.

We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. At times, we may also use IP addresses to collect information regarding the frequency with which you or other users browse various parts of the Site The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect and process information on our behalf.

We may store and use personal data to:

  • Track the usage of our Site, enforce our Terms of Use, keep the Site secure, prevent and detect fraud and abuse and to help us improve our services and understanding of the interests and needs of those who contact us;
  • Carry out our obligations arising from any contracts between you or the company you work for and us;
  • Provide you with the information and services that you request from us;
  • Guide us in answering your questions or to explore career, professional or business opportunities with you;
  • Develop analysis and business intelligence that enable us to operate, grow, protect, make informed decisions and report on the performance of our business; and
  • Pursue other legitimate interests of our own such as maintaining a database of contacts working with or in our industry for networking or business development purposes (unless such interests are overridden by your interests or fundamental rights or freedoms requiring protection of personal data).

PROTECTING PERSONAL DATA

We secure personal data against unauthorized or unlawful processing, and against accidental loss, destruction or damage by appropriate technical and organizational measures.

We evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal data.

We also take measures to ensure confidentiality, meaning that only people who have a need to know and use the personal data can access it.

Please be aware though that there is no such thing as “perfect security” on the internet, and third parties may unlawfully intercept or access transmissions or private communications. We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal data. You use our Site and send us information at your own risk.

DO NOT TRACK
We do not track visitors of the Site over time and across third-party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

SHARING YOUR PERSONAL DATA

We will never sell or disclose your personal data to nonaffiliated third parties, except as set forth below.

We may use or disclose certain personal data we collect about you or that you provide when you visit and browse the Site as part of our normal business operations, including to respond to requests from you. We may also use service providers in connection with the Site. These companies and individuals may have access to and use your personal data, as needed to perform their functions.

We will disclose personal data we collect from you when we believe that such disclosures are required by law, regulation, legal process, subpoena, document or governmental request. We may also do so to help enforce our Terms of Use, protect your safety or security, or protect the safety and security of tangible or intangible property that belongs to us, to you or to third parties. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Site and your experience.

We sometimes share personal data among the group of companies affiliated with Integrum. This may involve transferring your personal data from Integrum’s headquarters in New York to other countries where Integrum affiliates or other third parties operate and process your personal data. We also share personal data with vendors or agents working on our behalf for the purposes described in this Policy such as website hosting, maintenance, research and analytics solutions and IT services.

We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets, where we are required to do so by law, support auditing, compliance and corporate governance functions, in connection with legal proceedings or where disclosure is necessary to protect the vital interests of a person.

DATA RETENTION

How long will you use my information for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may continue to process such data for a longer period without further notice to you.

CHANGES TO YOUR INFORMATION
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your working relationship with us.

CALIFORNIA RESIDENTS

If you are a resident of the State of California, you have the right to request that we disclose to you or delete certain information about our collection and use of your “personal information” under California law. For purposes of the California Consumer Privacy Act (CCPA), personal information is data that identifies, relates to, or could reasonably be linked to an individual or household, but it does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Integrum may obtain the categories of personal data listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you purchase;
  • Indirectly from you. For example, technologically by collecting your IP address as you visit and browse pages on our Site; and
  • From third-party business partners such as social media sites (e.g., LinkedIn), ad networks, and analytics providers.

Please note that Integrum, in accordance with all applicable laws, will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Access to Specific Information and Data Portability Rights
You have the right to request that Integrum disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal data we collected about you.
  •  The categories of sources for the personal data we collected about you.
  • Our business or commercial purpose for collecting or selling that personal data.
  • The categories of third parties with whom we share that personal data.
  • The specific pieces of personal data we collected about you (also called a data portability request).
  • If we disclosed your personal data for a business purpose, a list identifying the personal data categories that each category of recipient obtained.

Deletion Request Rights
You have the right to request that Integrum delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal data, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you services.
  • Charge you different prices or rates for the services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of services.

EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

As used in this section, the terms “controller”, “processing” and “processor” have the meanings given to them in the GDPR. The term “personal data” has the meaning set out above in the section entitled “About This Policy”.

Who is the controller?
With respect to your personal data, Integrum is a “controller”. We ‘control’ the personal data that you have provided and make certain decisions on how to use and protect it – but only to the extent that we have informed you about the use or are otherwise permitted by law. We will only use personal data provided to us in a way that is consistent with this Policy.

The identity and contact details of the controller of your personal data are:

Integrum Holdings LP
Phone: +1 (212) 970-2500
E-mail: contact@integrumholdings.com
55 Hudson Yards,
47 Floor, Suite A
New York, NY 10001

Purposes for processing
The legal grounds we rely on for processing your personal data depend on the circumstances in which it is provided or acquired, but would typically fall within one or other of the following:

  • where information is provided for the purposes of a contract, the purpose for processing would be to perform a contract with you;
  • where personal data is processed for regulatory compliance or legal purposes it would be either to comply with a legal obligation to which we are subject or to pursue the legitimate interests of Integrum (unless those interests are overridden by your fundamental rights and freedoms); and
  • where personal data is collected for other business purposes (for example, for the purpose of corresponding with you, for carrying out and improving our business, analyzing the use of our website and our services, or to process and respond to an employment application), it would be to pursue our legitimate business interests (unless those interests are overridden by your fundamental rights and freedoms).

Categories of Data Recipients
The categories of recipients of your personal data are those described in the section above entitled “Sharing Your Personal Data”.

Transfers of Personal Data
If you transfer your personal data to us directly, you will be transferring such data voluntarily and entirely at your discretion to our offices in the United States. The United States does not have data protection and privacy laws that provide the same degree of protection as those in the European Economic Area (“EEA”) or the United Kingdom (“UK”).

If we were to process your personal data in the context of an establishment in the EEA or the UK and transfer your personal data to a recipient outside of the EEA and / or the UK, or if we are otherwise subject to restrictions on transfer of your personal data under equivalent laws of a country outside the EEA/UK (as applicable), we will only do so pursuant to a valid transfer mechanism such as:

  • an adequacy decision by the European Commission (or equivalent);
  • binding corporate rules;
  • data transfer agreements and/or safeguards using terms approved by the European Commission; and/or
  • other valid transfer mechanisms.

We currently have not entered into any such transfer arrangements.

Your rights in connection with personal data
To the extent applicable to the processing of personal data undertaken by Integrum, residents in the European Economic Area and in other countries that have adopted laws substantially similar to the GDPR (including the United Kingdom) may be entitled to exercise the following rights pursuant to the GDPR (or equivalent laws):

  • request access to the personal data we hold about you and request correction if any of the information we hold about you is incomplete or inaccurate,
  • request erasure of your personal data where there is no good reason for us continuing to process it,
  • object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground,
  • object where we are processing your personal data for direct marketing purposes,
  • request the restriction of processing of your personal data,
  • request the transfer of your personal data to another party; and
  • request that we transfer your personal to another organization (or directly to you), in certain circumstances.

Is it necessary to provide personal data?
Unless otherwise indicated, you should assume that any personal data we collect and process is for statutory, contractual requirements, or for our legitimate business interests or those of a third party (except where those interests are overridden by your interests, fundamental rights or freedoms).
To the extent that we request personal data from you for a legitimate purpose and you refuse to communicate that personal data to us, we may not be able to comply with our legal, regulatory or compliance obligations or enter into, or perform any contracts with you, which may affect our ability to maintain our business relationship with you.

Withdrawing your consent
We will not generally rely on your consent to process your personal data. However, if we do, you have the right to withdraw this consent at any time. If you wish to do so, please contact us as detailed in the ‘Contact Information’ below.

Automated Decision-Making
Integrum does not use automated decision-making technology or profiling.

Contact Information
If you believe you may be entitled to rights provided under the GDPR and want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact our Chief Compliance Officer (by phone: +1 (212) 970-2500 or by email: contact@integrumholdings.com) located at our headquarters in New York.

Complaints
In the event that you wish to make a complaint about how we process personal data about you, please contact our Chief Compliance Officer (by phone: +1 (212) 970-2500 or by email: contact@integrumholdings.com) located at our headquarters in New York and we will work to deal with your request as soon as possible. This is without prejudice to your right to raise a complaint with the data protection supervisory authority in the applicable country in which you live or work or where you think we have infringed data protection laws. A list of the EU data protection authorities is available via: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080. The United Kingdom, the relevant body is the Information Commissioner’s Office, please see https://ico.org.uk/make-a-complaint/.

GOVERNING LAW

The laws of the State of New York govern this Policy and your use of this Site in all respects. Any dispute relating to this Policy and your use of this Site shall be resolved solely in the state or federal courts located in New York, New York. You consent and submit to the personal jurisdiction of such courts for the purposes of any such dispute, controversy or claim and agree to waive trial by jury in any such dispute.

Last updated April, 2021