This Statement does not apply to (i) Vista personnel or job applicants seeking opportunities at Vista or (ii) information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”).
Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of personal information about you online or offline:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
- Commercial Information: commercial or investment information, including records of personal property, financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Sensory Information: audio, electronic, visual, and similar information
- Employment Information: professional or employment-related information
- Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
- Providing advertising and marketing services;
- Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
- Short-term, transient use, such as nonpersonalized advertising shown as part of your current interaction with us;
- Helping to ensure security and integrity;
- Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
- Debugging to identify and repair errors;
- Undertaking internal research for technological development and demonstration; and
- Managing our relationships with current or prospective corporate customers, vendors and other business partners.
We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.
To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.
Retention of Personal Information
Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.
- Directly from you, such as when you provide information through surveys, emails, calls, forms, and other features on our website
- From your devices, such as when you visit our website
- Our affiliates
- Our portfolio companies
- Businesses that we are evaluating in connection with a potential investment or business opportunity
- Recruiting agencies, social networks or other third-party websites
- Online advertising companies
Disclosure of Personal Information
During the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have disclosed your personal information with certain categories of third parties for a business purpose, as described below.
|Categories of Personal Information
|Categories of Third Parties
|Additional Data Subject to Cal. Civ. Code § 1798.80
In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement, we may have disclosed personal information about you to government entities and third parties in connection with corporate transactions, such as mergers, acquisitions or divestitures.
Sale or Sharing of Personal Information
We may share your personal information with certain third parties (such as certain advertising services) or otherwise allow them to collect your personal information via automated technologies on our site for cross-context behavioral advertising purposes in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you). This kind of sharing may be considered a “sale” or “sharing” under California law when the personal information is exchanged for non-monetary consideration. You have the right to opt out of this disclosure of your information, as detailed below.
We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this California Consumer Privacy Statement) the following categories of personal information to online advertising services:
- Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
- Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you.
Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.
Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or correction or deletion of your personal information, we may require you to provide additional information, including submitting a code that has been sent via email to the email address you provided. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, correction, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact [email protected] if you have any questions about this Statement or our information practices, or to request this Statement in an alternative format.
If you would like to make a request on your own behalf or submit a request as an authorized agent on behalf of another individual, please email [email protected].