Privacy Policy
Introduction
This Privacy Policy describes how Pamlico Capital Management, LP (“Pamlico,” “we,” “us,” or “our”) may collect, use, share, and otherwise process personal information when you visit our website at https://pamlicocapital.com/ (the “Website”) or in other contexts.
Please Note: If you are an individual investor in one of our Executive Funds, we also provide a separate, supplemental Privacy Notice that is posted conspicuously on our investor website with additional information about how we collect, share, and protect your nonpublic personal information. Please see our investor website for additional details and to review this additional Privacy Notice, or contact us at contactus@pamlicocapital.com if you have any questions regarding or difficulty accessing the additional Privacy Notice.
Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, you can choose not to use our Website. By accessing or using our Website, you agree to this Policy. This Policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes.
Personal Information We Collect about You and How We Collect It
As used in this Privacy Policy, personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (“Personal Information”). We may collect and process the following categories and examples of Personal Information about you:
• Identifiers, such as your name, address, email address, unique personal identifier, online identifier, Internet Protocol address, account name, Social Security number, driver’s license number, passport number or other similar identifiers;
• Personal information categories under California law, including name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, bank account number or other financial information (some personal information included in this category may overlap with other categories);
• Characteristics that are considered protected classifications under certain laws, such as national origin and marital status where relevant;
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Professional or employment information, such as your job title and place of work;
• Internet or other electronic network activity information, such as your internet protocol (IP) address, unique device identifiers, browser type and version, operating system and platform, and information about your interaction with the Website;
• Geolocation data, such as geographic location information about a particular individual or device; and
• Inferences drawn from any of the information described above to create a profile about an individual reflecting the individual’s preferences.
We may collect information that is considered “sensitive” under some data protection laws, such as your social security number. When we do so, we use such information only for lawful purposes in compliance with the applicable data protection laws, such as to perform the services requested by you and to resist malicious, deceptive, fraudulent or illegal actions, and we do not use such information to infer characteristics about you. Where required by applicable law, we will obtain your consent prior to processing such information.
When you visit our Website, we (or our third-party service providers acting on our behalf) may automatically collect your IP address or mobile device ID as you navigate through or interact with our Website, as described below. We may also collect any Personal Information you choose to give us if you decide to use the contact information on our Website to communicate with us by e-mail or telephone. We may also receive Personal Information from third parties or from publicly available sources, such as the organizations with which you are affiliated and from public databases and websites.
Additionally, as you navigate through and interact with our Website, we may automatically collect certain traffic data, usage information, and information about your computer equipment or mobile device, such as your browser and operating system. The technologies we use for this automatic data collection may include cookies that are stored on the browser of your computer or mobile device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code. We collect this information to manage our content and improve users’ use of our Website; count and review the number of users of our Website and their usage patterns; to track key performance indicators such as pages or videos accessed, frequency of access and other statistical information related to our Website (for example, recording the popularity of certain content and verifying system and server integrity); to identify the portion of users who accesses our Website via different web browsers; to recognize if a user is a return user of our Website; to store information about a user’s visits; to remember a user’s preferences; and for similar purposes in connection with monitoring, maintaining and improving our Website.
How We Use Your Personal Information
Generally
We may use the information we collect about you or that you provide to us, including Personal Information, to:
● Provide our Website and its contents to you.
● Provide, through our third-party service providers such as InvestorVision or Allvue, the LP Log-In platform linked through our Website.
● Provide you with information you request from us as well as informational content and marketing materials regarding the Website and our business.
● Provide you with support and to respond to your inquiries and customer service and support requests, including to investigate and address your concerns and to monitor and improve our responses.
● Update and maintain subscription or e-mail lists.
● Help maintain the safety, security, and integrity of our Website, databases and other technology assets and our business.
● Notify you about changes to our Website or this Policy.
● Comply with our legal obligations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions.
● Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes or obligations.
● Enforce any contracts between you and us, or for the establishment, exercise or defense of legal claims.
● Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information (including Personal Information) held by us is among the assets transferred.
● Fulfill any other purpose for which you provide the information.
● Serve any other purpose that we describe when you provide the information and for any other purpose with your consent.
Third-Party Websites
Our Website may include links to blogs, social media and third-party websites. These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any Personal Information. If you follow a link on our Website to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy.
Use and Disclosure of Aggregated or De-Identified Data
We may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user. We may use and disclose to third parties any such de-identified or aggregated data (including traffic and usage data that does not identify you personally) for any lawful purpose.
*Use of Google Analytics
*
We use Google Analytics to track and analyze certain traffic and usage statistics regarding the use of our Website, such as the number of visitors to our Website, how visitors are navigating to our Website, visitors’ general geographic region information, how long individuals are visiting our Website, and information about the equipment individuals are using to access our Website (e.g., browser version and operating system). We use this traffic and usage information internally, including to make improvements to our Website.
For more information, please review the following:
• Information about Google’s use of cookies: https://policies.google.com/technologies/cookies?hl=en-US
• Information about Google’s use of information from sites or apps that use Google’s services: www.policies.google.com/technologies/partner-sites
You can opt out of our use of certain Google Analytics features by enabling the Google Analytics Opt-out Browser Add-on in your browser (https://tools.google.com/dlpage/gaoptout). Because those opt-out and preference control pages are specific to the individual browser used to visit it, and because those pages are not operated by us, we are unable to perform the opt-outs on your behalf. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals.
Disclosure of Your Personal Information
Generally
We may share your Personal Information with third parties in the following circumstances:
● We may disclose Personal Information to any contractors, service providers and other third parties who need to know such information to provide services to us (e.g., that support our hosting, maintenance, operation and promotion of our Website and our permitted uses of Personal Information under this Policy).
● Additionally, if you are a user of our LP Log-In platform, the service provider that hosts and operates this platform may process your information in accordance with its privacy policy, which we encourage you to review for additional details.
● We may disclose Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction, and any due diligence review with respect to any such proposed transaction.
● We may disclose Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements and to respond to any government or regulatory request or audit.
● We may disclose Personal Information to enforce or apply any legal agreements between us and you (such as our Terms of Use), or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of Pamlico, our customers or others.
We may also disclose your Personal Information for any purpose disclosed when the information is provided, and for any other purpose with your consent.
We do not sell your Personal Information or share your Personal Information for purposes of cross-context behavioral advertising, and in the past 12 months we have not sold or shared any Personal Information to third parties.
Your Rights and Choices
Generally
You have certain choices regarding the Personal Information you provide to us. You can set your browser to refuse all or some browser cookies. If you choose not to accept cookies, you may be unable to access certain parts or pages of our Website, or certain parts, pages or features of our Website may not function properly. To learn more about cookies and how to disallow or manage them, go to: http://www.allaboutcookies.org/.
If you do not wish to have your Personal Information used by us to contact you with informational or promotional content or messages, you may send us an e-mail stating your request to contactus@pamlicocapital.com or you can opt-out by simply clicking on the “Unsubscribe” or “Updating your e-mail preferences” link in the most recent e-mail you received from us and follow the prompts that appear. This opt-out does not apply to notifications about changes to our Website or this Policy.
Please also refer to the section above titled “Use of Google Analytics” for more information regarding opting out of certain Google Analytics features used on our Website.
Data Subject Rights
Depending on your jurisdiction, you may have certain data subject rights, including under the California Consumer Privacy Act (CCPA). These rights vary by jurisdiction and may be subject to certain limitations and exemptions. These rights may include the right to:
● Know what personal information Pamlico collects, including (a) the right to request information regarding the categories of Personal Information that we collect along with other information such as the categories of sources from which the information is collected and third parties with whom it is shared and (b) the right to request a copy of the specific pieces of Personal Information that we collect (sometimes referred to as the right to access Personal Information);
● Correct or delete Personal Information;
● Opt out of the sale of Personal Information or sharing Personal Information for cross-context behavioral advertising – we do not sell Personal Information or share Personal Information for purposes of cross-context behavioral advertising, and so you are already opted out of such practices;
● Object to or restrict the processing of your Personal Information, including to limit the use or disclosure of sensitive personal information under certain circumstances; and
● Obtain a copy of your Personal Information in a portable format.
We will not discriminate against you for exercising applicable data subject rights. The rights described herein are not absolute, and we reserve all of our rights available to us at law in this regard. If you wish to exercise any of these rights, please email contactus@pamlicocapital.com or call us at (704) 414-7150. If you make a request related to Personal Information about you, we will need to verify your identity. For example, we may request that you match specific pieces of information you have provided to us previously to ensure that you are the individual whose Personal Information is the subject of the request. Similarly, we may limit our response to reasonably accessible data sources. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.
California “Shine The Light” Disclosure
The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. We do not currently disclose any Personal Information to third parties for their direct marketing purposes.
Users Outside of the United States
The Website is controlled, operated and administered by Pamlico from our offices within the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of our Website may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of Personal Information as the one in which you reside. However, we will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored or accessed.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age, and no one under age 16 may provide any information to this Website. We do not knowingly collect Personal Information from children under age 16. If you are under 16 years of age, do not use or provide any information on this Website. If we learn we have collected or received Personal Information from a child under 16 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under age 16, please contact us at contactus@pamlicocapital.com.
Data Security and Retention
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.
The safety and security of your information also depends on you. When we have given you (or when you have chosen) a password for access to certain parts of our Website, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information over the Internet is not completely secure. We cannot guarantee the security of your Personal Information or protect against unauthorized activity. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Website.
We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, or as long as we are legally required or permitted to do so. When deciding how long to retain your Personal Information, we take into account our legal and regulatory obligations, 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. We may also retain your Personal Information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
Changes to Our Privacy Policy
We may update this Privacy Policy from time to time and at our sole discretion. We post any changes we make to our Policy on this page. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Policy to check for any changes.
Contact Information
To ask questions or comment about this Policy and our privacy practices, you may contact us via e-mail at contactus@pamlicocapital.com, reach us via telephone at (704) 414-7150, or write to us by mail at 150 North College Street, Suite 2400, Charlotte, NC 28202.