Visitors that are residents of California should refer to our Website Privacy Policy Supplement for California Residents.
Visitors that are residents of the EU-UK should also refer to our EU-UK Privacy Notice.
OUR COMMITMENT TO PRIVACY
Your privacy is important to SUPPLY FACTORY HOLDINGS Partners, LP and its affiliates (together, “SUPPLY FACTORY HOLDINGS,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use personal information (which may be referred to in this Privacy Policy as “personally identifiable information”, “personal data” or other similar terms) for visitors of this website. Please read this Privacy Policy carefully. If you do not agree with the processing of your personal information in accordance with this Privacy Policy, please do not access or otherwise use this website. THE INFORMATION WE COLLECT AND HOW WE USE ITWe may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, SUPPLY FACTORY HOLDINGS’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (IP) addresses. SUPPLY FACTORY HOLDINGS generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” or “Email” page.
To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for SUPPLY FACTORY HOLDINGS’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as set out in this Privacy Policy, or as otherwise permitted or required by law or regulation.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
CAPACITY
You represent to SUPPLY FACTORY HOLDINGS that you have the authority to visit this website according to the Terms of Use. 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. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information. NOTIFICATION OF CHANGESWe reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes. MISCELLANEOUSThe provisions in our Terms of Use are hereby incorporated by reference. CONTACT USIf you have any questions or concerns about this Privacy Policy, please contact ir@Supply Factory Holdings.com.
WEBSITE PRIVACY POLICY SUPPLEMENT FOR CALIFORNIA RESIDENTS
Last Updated: January 22, 2024
This California Website Privacy Policy supplements the Website Privacy Policy 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 supplement is otherwise set forth above in the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (collectively, the “GLB Rights”), the GLB Rights shall apply.
Categories of Personal Information We Collect: We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
A. IdentifiersName, 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).Collected: YES
B. Additional data subject to Cal. Civ. Code § 1798.80Telephone 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).Collected: NO
C. Protected classification characteristics under California or federal lawDate of birth, citizenship and birthplace.Collected: NO
D. Commercial informationAccount 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).Collected: NO
E. Biometric informationImagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.Collected: NO
F. Internet or other similar network activityUse 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 inquiriesCollected: YES
G. Geolocation dataPhysical location or movements. Collected: NO
H. Sensory dataAudio, electronic, visual, thermal, olfactory, or similar information.Collected: NO
I. Professional or employment-related informationCurrent or past job history or performance evaluations.Collected: NO
J. 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.Collected: NO
K. Inferences drawn from other personal informationProfile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Collected: NO
L. Sensitive Personal InformationSocial 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.Collected: NO
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); To perform services on behalf of our business;To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; andTo collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.We do not knowingly collect or solicit personal information from anyone under the age of 18.
Purposes for Collecting Personal Information: We may collect or disclose the personal information we collect about you for one or more of the following business or commercial purposes:Performing services for you;Improving our Website and the products and services that we offer and notify you about changes to our products and services;Communicating with you, including responding to requests for information submitted by you through our Website;Keeping a record of your relationship with us;Ongoing operations, administrative, accounting, reporting, account maintenance, and other processes;Auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;Maintaining the safety, security and integrity of our products and services, databases, technology assets and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;Complying with U.S., state, local and non-U.S. laws, rules and regulations.
We retain the categories of personal information set forth above in the “Categories of Personal Information We Collect” section of this Privacy Notice supplement only as long as is reasonably necessary for those purposes set forth above, except as may be required under applicable law, court order or government regulations.
Disclosure of Information: We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
We disclose, or, during the past twelve (12) months, have disclosed personal information collected from you for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
A. IdentifiersAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
C. Protected classification characteristics under California or federal lawAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
D. Commercial informationAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
E. Biometric informationN/A
F. Internet or other similar network activityAdministrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.
G. Geolocation dataN/A
H. Sensory dataN/A
I. Professional or employment-related informationN/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))N/A
K. Inferences drawn from other personal informationN/A
L. Sensitive Personal Information N/A
Rights under the CCPADeletion Rights:
You have the right to request that we delete any of your personal information that we retain, subject to certain 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 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;Categories of third parties with whom we disclose the personal information;The specific pieces of personal information we have collected about you; andWhether we disclosed your personal information to a third party, and if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information 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: If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email to SFH@SupplyFactoryHoldings.com.
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 us at SFH@SupplyFactoryHoldings.com. with any questions about this Privacy Notice supplement.
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