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Frontier Growth Data Privacy Notice

April 2021

This is the Data Privacy Notice (“Privacy Notice”) of FC Capital Management, LLC (d/b/a Frontier Growth) and its affiliate and subsidiary entities (“Frontier” or “the Company”). We maintain a website to provide services to you. This website may ask for and collect your personal information to provide our services, enhance your experience, and provide you with other relevant information about our offerings. This Privacy Notice applies to activities Frontier engages in on its website and activities that are offline or unrelated to its website. We are providing this notice to explain our information practices and the choices you can make about the way your information is collected and used.

This Privacy Notice governs our treatment of personal information. We expect all of our employees and those with whom we share personal information to adhere to this Privacy Notice.

Frontier is committed to protecting the information that our investors, business partners, employees, suppliers, and others have entrusted to us.

This Privacy Notice applies to all personal information collected by Frontier, relating to all investors, business partners, suppliers, and others who do business with us.

Personal Information We Collect and Use

We only collect personal information that you provide to us or that we are authorized to obtain by you or by law. The types of personal information we collect will depend on how you are interacting with us through our website or in person. For example, we may collect different information from you through recruiting than if we are exploring a new business relationship or venture with you. Depending on our interactions, we may collect the following categories of personal information:

  • When you contact us with questions: We may collect your name, email address, and phone number from you to respond to your questions;
  • When we need to make a payment or distribution: We may collect your name, bank account number, and routing number from you in order to make the payment or distribution;
  • When you become a Limited Partner or Investor: We may collect your name, title, signature, address, Social Security number or Tax Identification number, phone number, email address, bank account number, routing number, ABA number, fax number, and qualified status information from you or your attorney to perform diligence, to comply with legal obligations, to communicate with you, to prepare our tax information, and to comply with reporting requirements;
  • To prepare fund financials and metrics and to facilitate capital calls: We may collect your name, bank account number, and routing number from you to manage and administer the investment funds;
  • To manage our portfolios and funds: We may collect your name, investment amount, tax ID, fund information, and customer list information including name and contract amount from you or from your attorney;
  • When we register you for events: We may collect your name and email address from you to register you for the event and to send you any requested notes or information from the event;
  • When we are evaluating potential employment candidates or candidates for investment: We may collect your name, education history, address, phone number, email, employment history, gender, ethnicity, and veteran status from third party recruiters or databases, social and professional networking sites, and common partners/acquaintances to perform executive searches for our portfolio companies, to learn more about investment opportunities, and to communicate with you;
  • When we perform diligence on potential portfolio companies: We may collect your name, employment information, compensation information and structure, general location, credit agreements, mortgages, indentures, loans, guarantees of third party obligations, equipment leases and other financing arrangements, tax returns, I-9 verification information, and Social Security numbers from you or your employer;
  • When we perform background checks: We may collect your name, address, phone number, date of birth, email address, government identification numbers, sex or gender, insurance numbers, Social Security number, criminal records, driving records, and employment information from our background search vendors;
  • To monitor for SEC compliance obligations: We may monitor email communications of Limited Partners, to the extent they are corresponding with our employees;
  • When you interact with us through our website: We may collect your IP address, information regarding your interaction with our website, or network location based on your IP address;
  • To operate, evaluate, and improve our business, including improving and personalizing the experience for you and others;
  • Using Data Analytics to audit, research, and conduct analysis in order to maintain and improve our services and to protect people who use our website;
  • For safety and security, by making sure third parties protect your information, and monitoring the technical functioning and security of our network;
  • For legal and compliance, including complying with applicable laws, regulations, and legal obligations; and
  • To protect the rights or property of the Company, as well as its employees, partners, and people who use its website.

We do not sell any personal information from individuals to third parties.

How We May Use Your Information

Your privacy is important to us. We collect and use information we need to do our business, including providing you with the services and experiences you expect from us. When we collect and use your information, we take your privacy and security seriously.

We will use the information provided by you, or on your behalf, to provide our services or evaluate potential business relationships. Specifically, we have used your personal information for the following purposes within the twelve (12) months preceding the date of this Notice:

A: Identifiers

  • Types of Information Collected: 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.
  • Purpose for Collection: Communications, distributions and payments, investors / LPs, fund financials, portfolio management, events, candidate search, diligence, background checks, SEC compliance.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

  • Types of Information Collected: Name, signature, Social Security number, 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, or health insurance information. Some personal information included in this category may overlap with other categories.
  • Purpose for Collection: Communications, distributions and payments, investors / LPs, fund financials, portfolio management, events, candidate search, diligence, background checks, SEC compliance.

C. Protected classification characteristics under California or federal law.

  • Types of Information Collected: Age (40 years or older), race, color, ancestry, national origin, citizenship, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
  • Purpose for Collection: Candidate search diligence.

D. Commercial Information

  • Types of Information Collected: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Purpose for Collection: Diligence.

E. Internet of other similar network activity

  • Types of Information Collected: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Purpose for Collection: Website.

F. Geological data

  • Types of Information Collected: Physical location or movements.
  • Purpose for Collection: Website.

G: Professional or employment-related information

  • Types of Information Collected: Current or past job history or performance evaluations.
  • Purpose for Collection: Candidate search diligence, background checks.

Cookies and Similar Technologies

A “cookie” is a small text file that websites send to your computer, device, or other Internet- connected device to identify your browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and the cookies and may be used to transmit information collected through cookies back to a web server.

Our sites use cookies, web beacons, java scripts, and similar technologies to collect certain information about your activity relating to your visit to our website. These technologies collect your Internet Protocol (IP) address, network location, and information about your interaction with our website. We use this data to analyze trends, administer our sites, track users’ movements through our website, and gather demographic information about our partners as a whole. We may receive reports based on these technologies on an aggregated basis.

Behavioral Tracking/Third Party Cookies

We use third-party analytics services on our website, including Google Analytics. To learn more about Google Analytics, visit: https://policies.google.com/technologies/partner-sites.

Your Internet browser may let you restrict or disable certain types of cookies. Without cookies, you may not be able to use all of the options on our website.

Some web browsers allow you to turn on Do Not Track (“DNT”), which sends signals to websites you visit, telling those sites that you do not want your online activities to be tracked. Our website currently is not designed to respond to DNT signals received from web browsers.

We may also use JavaScript to help our website, especially pictures, function better. You can turn JavaScript on or off in your browser functions, but if you turn it off, you may not be able to use all of the options on our website.

Sometimes we use technology to collect the information that your browser uses to auto-fill. You can stop this technology by turning it off in your browser, and you will still be able to use all of the options on our website.

How We Share Personal Information

We may share information about you to third parties as indicated below:

Affiliates, Subsidiaries, and Portfolio Companies: We may share your personal information with our different affiliates, subsidiaries, and portfolio companies. If we share your information, we will share only the information that is necessary and we will take reasonable steps to make sure that third parties take prudent steps to protect your information.

Investment Subject Matter Experts: We may share your personal information with different subject matter experts in the course of a financial transaction or investment, including attorneys, brokers, investment bankers, accounting firms, insurance specialists, market or technology consultants, and HR consultants, among others. These people will only use your information to the extent necessary to undertake diligence and consummate the transaction.

Service Providers, Suppliers, Agents, and Business Partners: Other companies sometimes provide certain services to us or on our behalf (e.g., maintenance, IT support, analysis, development, security, background checks, technical solutions for transactions). Unless we tell you differently or as described elsewhere in this Privacy Notice, our service providers are not permitted to use your information except to assist us.

Compliance with Legal Obligations: We may need to disclose certain information to auditors, government authorities, law enforcement, regulatory agencies, our legal counsel, third party litigants and their counsel, or other authorized individuals in order to comply with laws that apply to us, or other legal obligations such as contractual requirements.

Changes in Business Structure/Ownership: We may disclose or transfer your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of the Company’s business, assets, or ownership interest (including any bankruptcy or similar proceedings).

We have not sold any categories of personal information within the past 12 months, including children’s personal information.

Information We Disclose for a Business Purpose

In addition to the purposes described in this notice, we may use personal information listed below for business purposes.

  • To make distributions or payments, we may share the following categories of information: Identifiers, California Consumer Records Categories
  • To submit government or agency-required filings, we may share the following categories of information: Identifiers, California Consumer Records Categories, Protected Classifications
  • To perform diligence throughout the course of a purchase, investment, or capital raising transaction, including to comply with anti-money laundering regulations, we may share the following categories of information: Identifiers, California Consumer Records Categories, Commercial Information, Professional or Employment-Related Information
  • For our accounting needs in the course of our business, we may share the following categories of information: Identifiers, California Consumer Records Categories
  • To share information with prospective investors, we may share the following categories of information: Identifiers, California Consumer Records Categories
  • When we are evaluating potential employment candidates or candidates for investment, we may share the following categories of information: Identifiers, California Consumer Records Categories, Commercial Information, Professional or Employment-Related Information
  • To facilitate registration and management of in-person or virtual events, we may share the following categories of information: Identifiers, California Consumer Records Categories
  • To provide you with services, including customer service, processing transactions, verifying consumer information, and processing payments, we may share the following categories of information: Identifiers, California Consumer Records Categories
  • To improve our website, including responding to inquiries and improving functionality, we may share the following categories of information: Internet Activity, Geolocation Data
  • To comply with your requests, including sending your information to third parties if you ask us to do so, we may share the following categories of information: Identifiers, California Consumer Records Categories

How We Protect Personal Information

We strive to take appropriate security measures to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are allowed to access personal information, and they may only access it for permitted business functions. We also use technology to protect your information, including firewalls and encrypting sensitive personal information that is transferred to or from our systems.

While we cannot guarantee that loss, misuse, or alteration will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our services and provision of information to us is at your own risk.

Our website may contain links to other third-party sites on the Internet. The information practices of those websites are not covered by this Privacy Notice. We are not responsible for the privacy policies of other websites.

California Privacy Notice

Your Rights and Choices

For all personal information that we collect about you, you may have the following rights or choices that we will accommodate where your requests meet legal and regulatory requirements and do not risk making our other data less secure or changing our other data. You may also designate an authorized agent to make a request on your behalf.

Access: You may have the right to know what information is being collected about you, to access your personal information, to receive a copy of your information, and to know whether your personal information is disclosed and to whom. If you have questions about your information, please contact us using the methods in the Contact Us section below.

Erase: You also may request that we erase your information. If you want to ask us to erase your information, please contact us using the methods in the Contact Us section below.

Data Portability: You may have the right to ask for a copy of the personal information we have about you. If you would like to request that we provide a copy of your information to you, please contact us using the methods in the Contact Us section below.

Non-Discrimination: You have the right not to receive discriminatory treatment by the Company because you exercise your privacy rights. If you have any questions, please contact us using the methods in the Contact Us section below.

How to Make a Request: If you would like to make a request, please use the Contact Us section at the bottom of this page. Please provide your full name, phone number, and email address.

Responding to Requests: Your request will be evaluated to determine whether the requested change meets legal regulatory requirements and does not risk making our other data less secure or changing our other data. After we evaluate your request, we will respond to update you on the status of your request.

Verifying Your Identity: To protect you and your information, we may ask you to confirm certain information before we honor your request. For example, if you make a request, we will ask you to confirm your name, email address, and/or phone number verify your identity, so that we can help protect your information. If you designate an authorized agent to make a request on your behalf, we may require you to verify your identity and provide the authorized agent’s identity and contact information to us.

European Privacy Notice

International Data Transfers

Frontier primarily stores the Personal Information we collect in the United States. To facilitate Frontier’s global operations, staff who work for Frontier and/or our service providers may transfer and access such Personal Information from locations around the world. This will involve transferring your Personal Information outside the European Economic Area (EEA).

We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Notice.

Whenever we transfer your Personal Information out of the EEA, we will ensure one of the following safeguards is implemented:

  • We will only transfer your Personal Information to countries that have been deemed to provide an adequate level of protection for Personal Information by the European Commission; or
  • We may use specific contracts approved by the European Commission which give Personal Information the same protection it has in Europe; or
  • We will ensure there is some other protection in place which has been approved by the European Commission as giving Personal Information the same protection it has in Europe.

E.U. Privacy Rights

Under certain circumstances, individuals within the European Economic Area have rights under data protection laws in relation to your Personal Information as set out below:

  • Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Legal Bases For Processing

We have set out below a description of some of the legal bases we rely on to process your Personal Information. Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your Personal Information. Please email: privacy@frontiergrowth.com or write to Frontier, Attn: Privacy Compliance at 525 North Tryon Street #1900, Charlotte, NC 28202 if you need details about the specific legal grounds we are relying on to process your Personal Information where more than one ground has been set out below.

  • Contracts. Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate Interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. The following are non-exhaustive examples of where Frontier relies on legitimate interest to process Personal Information:
    • Frontier has a legitimate interest in processing Personal Information during the employee recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and decide to whom to offer a job.
    • Frontier has a legitimate interest in processing Personal Information relating to our existing and potential investment partners in order to manage our business relationship and provide communications and information that may be of interest, including marketing communications.
    • Frontier has a legitimate interest in using cookies as outlined above in the cookie section of this Privacy Notice.
  • Legal Obligations. Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your Personal Information.

Data Retention

We will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Currently, we keep most information for the entire lifecycle of an investment fund in order to satisfy legal, accounting, and reporting requirements.

In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Changes To This Notice

We reserve the right to modify or change this Privacy Notice at any time. When we make a material change to this Privacy Notice, we will inform you by posting a prominent notice on the home page of our website or changing the date on this page noting when the Privacy Notice was last updated.

Contact Us

For questions regarding this Privacy Notice or to submit any of the requests mentioned above relating to your personal information, contact us using any of the following options:

Mail
525 North Tryon Street #1900 Charlotte, NC 28202

Email
privacy@frontiergrowth.com

Telephone
704-414-2880