Pacific Lake Partners Website Privacy Policy: Your Privacy Rights
Last Modified: August 1, 2023
Pacific Lake Partners, LLC (“Pacific Lake” or “PLP”) knows that your privacy is important to you, and we want you to know that it is important to us too. This Privacy Notice (“Notice”) describes the types of information we may collect from you or that you may provide when you visit the website www.pacificlake.com (our “Site”) and our practices for collecting, using, maintaining, protecting, and disclosing that information, and how you can opt out of some of our uses and disclosures of your information. This Notice 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 Notice as they may be amended from time to time.
Here are a few general principles to keep in mind as you read through this Notice:
- The Site is owned and operated by Pacific Lake Partners, LLC, referred to collectively in this policy as “we,” “us,” “our” and other similar pronouns.
- As our business evolves, this Notice may change, so check back to this page periodically to make sure you understand how your personal information will be treated.
This Notice 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 can also opt-out of our promotional emails by clicking on the opt-out link within the e-mail you receive.
Children Under the Age of 16
Our Site is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at:
Pacific Lake Partners, LLC
Prudential Tower
800 Boylston Street, Suite 2220
Boston, MA 02199
accounting.ops@pacificlake.com
617-658-3024
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.
What information is collected on this Site?
We collect several types of information from and about users of our Site, including information:
- By which you may be personally identified, such as name, postal address, e-mail address, telephone number, company name, professional title, or any other identifier by which you may be contacted online or offline ("personal information");
- That is about you but individually does not identify you; and/or
- About your internet connection, the equipment you use to access our Site, and our usage details.
We collect this information:
- Directly from you when you provide it to us (e.g., User-Provided Information).
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
User-Provided Information
We collect Personal Information such as your name; postal addresses; educational information; 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.
Automatic Data Collection and Site Usage Information
We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with the Site, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer, and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information(e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Internet activity or electronic network activity information that we collect about your interaction with our Site, emails, and other online content, such as the pages you viewed, emails you opened, links you clicked, how long you spent on a page, navigation paths between pages or screens, information about your activity, your preferences, access times, and duration of access.
- Communication interaction data such as your interactions with our email, voicemail, text, or other communications (e.g., whether you open and/or forward emails) – we may do this through the use of pixel tags(which are also known as clear GIFs), which may be embedded invisibly in our emails.
Among other things, this automatic data and site usage 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 Website. 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.
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 Automatic Data and Site Usage Information to perform the following business functions:
- providing you with our services
- enabling users to use our Site and its features
- responding to your requests, questions, and concerns
- verifying User information
- internal research for technology development and demonstrations, and to develop, improve, upgrade, and enhance new features and offerings for our Users
- 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
- 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
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 may use your personal information for reasons not described in this Notice where permitted by law and when the reason is compatible with the purpose for which we collected it. In some cases, we may specifically ask you for your consent to collect, use or share your personal information, such as where required by law.
Retention
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require your personal information we have collected we may we may either delete it or de-identify, aggregate or anonymize it. If we de-identify, aggregate, or anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
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 Pacific Lake Fund has invested, and to the sponsors of such entities;
- 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, dissolution, or similar corporate restructuring of our 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.
What are Your Choices?
Opt-out of communications
You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, emailing us at accounting.ops@pacificlake.com, or calling us at: (617) 658-3024. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Do Not Track
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: Pacific Lake Partners, LLC, Prudential Tower, 800 Boylston Street, Suite 2220, Boston, MA 02199 or by email: accounting.ops@pacificlake.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.
Declining to provide information
We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Choices About How We Use and Disclose Your Information
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 using the information in the “Contact Us” section below. 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.
Your State Privacy Rights
Residents of certain states, such as California, Nevada, Colorado, Virginia, and Utah may have additional personal information rights and choices. To learn more about California residents' privacy rights, see our CCPA Privacy Notice. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the address in the Contact Us section below.
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
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 accounting.ops@pacificlake.com. You can make this election at 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.
Other Sites and Services
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 Notice
We may change this Notice from time to time. When we do, we will let you know by posting the changed Notice 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 2220
Boston, MA 02199
accounting.ops@pacificlake.com
617-658-3024
PACIFIC LAKE PARTNERS, LLC
CCPA AND CPRA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: August 1, 2023
This CCPA and CPRA Privacy Notice for California Residents (“CA Notice”) supplements the information contained in Pacific Lake Partners, LLC (“Pacific Lake” or “PLP”) Notice and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CPRA”) (collectively “CCPA”), and its implementing regulations. (CCPA) and any terms defined in the CCPA have the same meaning when used in this CA Notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:
-Publicly available information from government records.
-Deidentified or aggregated consumer information.
In particular, we collected the following categories of personal information from consumers within the last twelve (12) months:
Category Identifiers
Examples A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Collected YES
Category Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected YES
Category Protected classification characteristics under California or federal law.
Examples Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected YES
Category Commercial information.
Examples Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected NO
Category Biometric information.
Examples Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, ad voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data
Collected NO
Category Internet or other similar network activity.
Examples Browsing history, search history, and information on a consumer's interaction with a website, application, or advertisement.
Collected YES
Category Geolocation data.
Examples Physical location or movements.
Collected NO
Category Sensory data.
Examples Audio, electronic, visual, thermal, olfactory, or similar information.
Collected NO
Category Professional or employment-related information.
Examples Current or past job history or performance evaluations.
Collected YES
Category Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples 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
Category Inferences drawn from other personal information.
Examples Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected NO
We collect the categories of personal information listed above from the following categories of sources:
- Directly from you.
- Indirectly from you. For example, from observing your actions on our website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information.
- To provide, support, personalize, and develop our website, products, and services.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- In connection with a corporate change, dissolution or similar corporate restructuring of our business.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We do not sell your personal information. However, we may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we disclosed personal information for a business purpose in the following categories from the chart above: A and B. We disclosed this information to our affiliates, third-party services providers, business transferees, and professional advisors.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or 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.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 et. seq.).
5. Comply with a legal obligation.
6. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request at:
Pacific Lake Partners, LLC
Prudential Tower
800 Boylston Street, Suite 2220
Boston, MA 02199
accounting.ops@pacificlake.com
617-658-3024
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us.
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
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.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years old. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) please submit a request at:
Pacific Lake Partners, LLC
Prudential Tower
800 Boylston Street, Suite 2220
Boston, MA 02199
accounting.ops@pacificlake.com
617-658-3024
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Changes to Our CA Notice
We reserve the right to amend this CA Notice at our discretion and at any time. When we make changes to this CA Notice, we will post the updated notice on the website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in our Notice, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
Pacific Lake Partners, LLC
Prudential Tower
800 Boylston Street, Suite 2220
Boston, MA 02199
accounting.ops@pacificlake.com
617-658-3024
If you need to access this CA Notice or our Notice in an alternative format due to having a disability, please contact us at the address above.