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”).
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.
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
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.
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:
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.
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 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.
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.
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:
Integrum may obtain the categories of personal data listed above from the following categories of sources:
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:
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:
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:
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.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
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
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:
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:
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):
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.
Integrum does not use automated decision-making technology or profiling.
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: email@example.com) located at our headquarters in New York.
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: firstname.lastname@example.org) 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/.
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