Pacific Lake Partners Web Site Privacy Policy: Your Privacy Rights

Pacific Lake Partners knows that your privacy is important to you, and we want you to know that it is important to us too.  We created this Privacy Policy (“Policy”) to explain the types of information we collect through our Web sites on which it is posted (individually a “Site” and collectively “Sites”), how we will use, disclose and protect this information once it is collected, and how you can opt-out of some of our uses and disclosures of your information. This Policy serves as a supplement, and is not intended to replace, the Pacific Lake Partners Privacy Notice that applies to limited partners in PLP funds who are individuals. By visiting our Site, you agree to the terms of this Privacy Policy as they may be amended from time to time.

Here are a few general principles to keep in mind as you read through this Policy:

  • The Site is owned and operated by Pacific Lake Partners, referred to collectively in this policy as “we,” “us,” “our” and other similar pronouns.
  • As our business evolves, this Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.

This Policy does not apply to information that you may provide to us, or that we may obtain, other than through our Site, such as over the phone, by mail, or in person.

  • If you are located outside of the United States, you should know that the information you provide to us is being transmitted to us and processed in the United States and will be protected subject to this privacy policy and United States laws, which may not be as protective as the laws in your country.  Also, this Site places cookies and local shared objects on your computer or device which are further described below.  By using the Site, you agree to this. 

Opt In and Opt Out

You may have the right to opt in to or opt out of certain of our uses and disclosures of your Personal Information.  For example, when you are asked to provide Personal Information on this Site, you may have the opportunity to elect to, or not to, receive messages from us by e-mail. You may tell us that you do not want to receive our promotional messages, by sending us your name, address, e-mail and phone number to: rob.morgan@pacificlake.com.  You can also opt-out of our promotional emails by clicking on the opt-out link within the e-mail you receive.  Please understand that it may take us a few days to process any opt out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.  Also, to stop receiving promotional messages from third parties who already have your contact information, please contact them directly.

What information is collected on this Site?

“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect different categories of Personal Information from different sources, including User-Provided Information and Site Usage Information.

User-Provided Information

We collect Personal Information such as your name; postal addresses; e-mail addresses and telephone numbers. For example, we collect Personal Information when you submit a comment or question to us using a “contact us” or similar feature on the Site.

Information you are required to provide to us in order to make your request is indicated with an asterisk next to the field on our online forms.  In those cases, you are not required by law to provide the information, but if you do not provide the information, we may not be able to respond to your request.  An example of this is your email address when you sign up to receive emails from us. 

Site Usage Information

As is the case with many Web sites, our servers automatically collect your IP address when you visit our Site, and we may associate that with your domain name or that of your Internet access provider.  We may also capture certain “clickstream data” pertaining to your Site usage.  Clickstream data includes, for example, device ID and other information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next Web site you visit when you leave the Site, and any search terms you have entered on the Site or a referral site. 

Among other things, this information enables us to generate analytics reports on the usage of our Site. To opt-out of your Site usage being included in our Google Analytics reports, you may follow these instructions.

In addition, we may deploy various tracking technologies on the Site to collect additional information about your Site visits.  For example:

  • Cookies are small data files stored on your computer or device at the request of a Web site. A cookie assigns a unique numerical identifier to your Web browser, and may enable us to recognize you as the same user who was at our Site in the past, and relate your use of the Site to other information about you, such as your Site usage information and Personal Information.  Cookies may also be used to enhance your experience on the Site or to collect general usage and aggregated statistical information and detect and prevent fraud.  Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features. 
  • Local shared objects, such as “Flash cookies,” may be stored on your computer or device using a media player or other software installed on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way.  Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings.  For information on managing Flash cookies, for example, click here. 
  • HTML5 (the language some Web sites are coded in) may be used to store information on your computer or device about your Site usage activities. This information can be retrieved by us to determine how our Site is being used by our visitors, how it can be improved, and to customize it for our users.
  • A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number or persistent identifier to you, your household or device and relate your Site Usage Information to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access our Site using different Web browsers and different computers or devices.

How is your information used?

We or our service providers may use the Personal Information we collect from and about you, including User-Provided Information and Site Usage Information to perform the following business functions:

  • providing you our services
  • enabling users to use our Site and its features
  • responding to your requests, questions, and concerns
  • verifying investor information
  • internal research for technology development and demonstrations, and to develop, improve, upgrade and enhance new features and offerings for our investors
  • developing new features and offerings on the Site
  • send you information about the services. You may opt out of receiving such notices from us by following the instructions in the Opt In and Opt Out section above.
  • auditing compliance and other practices
  • protecting our rights and property
  • recovering debt and preventing fraud
  • customizing our Site to your interests and history with us
  • analytics
  • detecting security incidents
  • protecting against bad activity
  • bringing claims against wrongdoers
  • quality and safety assurance measures
  • debugging software, systems and practices
  • other purposes disclosed when personal information is submitted to us
  • other limited transactional uses

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources and publicly accessible information (such as information available publicly on the Internet). This information includes, for example, demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.

Do we share Personal Information and Site Usage Information with others?

Yes.  We may share the information we collect with others for a variety of reasons. We may share your information (including any of the types listed in the “What information is collected on this Site?” section above):

  • To our affiliates and service providers (e.g., our attorneys, accountants and auditors, lending institutions, third party administrators and record keepers for our funds, and entities that assist us with the distribution of stock to our investors), to the entities into which a PLP Fund has invested, and to the sponsors of such entities;
  • Consistent with industry practice, to the other investors in the PLP Funds in which you participate (such as your name, address and the amount of your capital commitment);
  • At your direction or with your consent, including upon your authorization to disclose such information to persons acting in a fiduciary or representative capacity on your behalf;
  • To respond to a subpoena or court order, judicial process or regulatory inquiry;
  • in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business

In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.

Do Not Track Disclosures

Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  We currently do not change our tracking practices (which are explained in more detail under “Site Usage Information” above) in response to DNT settings in your web browser. 

Our third party partners collect information about your online activities over time and across our Site and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings.

Your Access Rights

You may request that we update or delete certain of your Personal Information and Site Usage Information, subject to some conditions, by contacting us at: rob.morgan@pacificlake.com.  We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete your information is subject to our records retention policies and applicable law.

If you are a registered user that is a California resident under the age of 18, you may contact us at rob.morgan@pacificlake.com to request that we remove specific content or information that you have posted to the Site.  Upon our receipt of your request, once we have identified the specific information or content you would like removed, we will make such information or content no longer visible to other users of the Site or to the public.  Removal will not ensure complete or comprehensive removal of the content or information posted on our Site, for example, if applicable law requires us to maintain the information or content, or if the information or content was posted by another registered user, or if the information or content is anonymized so that you cannot be individually identified.

Security

While we endeavor to protect the security and integrity of sensitive Personal Information collected via this Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. 

If you correspond with us by e-mail or using Web forms like a “contact us” feature on our Site, you should be aware that your transmission might not be secure.  A third party could view the information you send in transit by such means.  We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If at any time during or after our relationship we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development.  If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances.  If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us.  If you receive a notice from us, you can print it to retain a copy of it.  To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at  rob.morgan@pacificlake.com.  You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request.  You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.  

“Linked-To” Web Sites

The Site may contain links, banners, widgets or advertisements that lead to other Web sites.  We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them.  We encourage you to read the privacy statements of each Web site visited after leaving the Site to learn about how your information is treated by others.

Changes to this Privacy Policy

We may change this Policy from time to time.  When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date.”  In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you.   In some cases, we may request your consent to the changes.

Contact Us

If you have any questions or comments regarding our privacy practices, you may contact us at:

Pacific Lake Partners, LLC
Prudential Tower
800 Boylston Street, Suite 220
Boston, MA 02199
U.S.A.

Email: rob.morgan@pacificlake.com

Phone:  (617) 658-3024

Effective Date:  March 1, 2019