Privacy Policy

This Privacy Policy governs this website (the “Site”) of TSG Consumer Partners, LP and its affiliates (together, “TSG,” “we” or “us”). We respect your privacy as a user of the Site. This Privacy Policy describes whether and how we collect and use information about you when you visit the Site, as well as certain offline collection as specifically described below.

Your visit to the Site is subject to this Privacy Policy. By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time and constitutes a legal agreement between you and TSG. We will post any updates to this Privacy Policy here, and any updates will be effective upon posting. You should consult the Privacy Policy on this Site each time you visit the Site. If you do not agree with its terms, please do not use the Site.

This Privacy Policy does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you are comfortable with their terms. Further, this Privacy Policy does not govern information that you submit to TSG in your role as an investor in TSG or in funds that we sponsor or manage. We address these practices in separate notices. This Privacy Policy does not apply to information we collect from our employees, applicants for employment, contractors, or business contacts. Additional information relevant to California residents regarding our practices under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”) is described below in our California Privacy Statement.

When we use the term “personal information” in this Privacy Policy, we mean 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.

 

I. The Types of Information We Collect About You

Information We Collect on the Site

When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect through technology.

Information You Provide to Us. To obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to identify you personally, including your name, e-mail address, company name, and title. Additionally, we may collect and retain a record of all communications with you.

Information We Collect Through Technology. We may collect information about you through technology. For example, we may collect your IP address each time you request a page during a visit to the Site. (An IP address is often associated with the portal through which you enter the Internet.) At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.

The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send to our Site users to determine whether such users have opened those e-mails and/or clicked on links in those e-mails.

We use software tools such as Google Analytics to measure and collect session information about your Site visits, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

We may use the information described to understand better how our visitors use the Site, research our visitors’ demographics, interests, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may combine this information with personal information. We may use this information in any manner permitted by law, but any disclosure that identifies you personally will be governed by this policy.

Information We Collect From Business Contacts

We receive certain business contact information, such as information about employees of our vendors or institutional investors.  In some situations, we may receive such information from third parties.  The information we receive about business contacts typically includes identifiers like your name, business address, email, or telephone.  We use this information to interact with you and to operate our business.

Information We Collect When You Visit Our Offices

When you visit one of our offices, we may receive personal information about you.  This may include identifiers such as your name, business address and telephone, for example, when you check in, as well as visual information collected via security cameras. We use this information to manage our offices and protect the property and safety of our personnel and others.

 

II. Do Not Track Signals

TSG does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You should consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

 

III. Children

Although this Site is not targeted toward children, we are concerned about the safety and privacy of children who use the Internet. We do not knowingly collect personal information from children under the age of 16, nor do we disclose such information to third parties. However, if a child under the age of 16 provides personal information to us through the Site, a parent or guardian may inform us at the address for legal notices below, and we will allow the parent or guardian to review the information and will delete it from our database, subject to applicable law.

 

IV. International Use

Our databases are located in the United States, and your data is stored in the United States. If you access this website from outside the United States, you do so at your own risk and are responsible for compliance with local laws, rules and regulations. By sending us your data, you consent to its transfer to and storage within the United States.

 

V. Cookies and How We Use Them

Cookies are small text files that may be placed on your browser when you visit our Site. Cookies are used primarily for administrative purposes, to improve your experience with our Site. For instance, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are.

TSGConsumer.com uses cookies primarily to capture anonymous analytics to improve your experience with the Site and its performance. This includes compiling statistical information concerning, among other things, the frequency of use of our site, the pages visited, and the length of each visit, as well as information about your computer, operating system, browser, language, and country.

Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. Consult your browser’s Help menu to learn the correct way to modify your cookies. If you choose to turn off cookies, you may not have access to many features that make your browsing of our Site smoother, and some of our services may not function properly. You may at any time delete any cookies set by us by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. If you would like to modify your browser to notify you when you receive a new cookie or to disable cookies altogether, please refer to https://www.aboutcookies.org. If you continue without changing your settings, we’ll assume that you accept receipt of all cookies on the Site.

As mentioned above, we use Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at www.google.com/policies/privacy/partners/. By using the Site with your browser set to accepting cookies, you consent to our and Google Analytics’ use of cookies on the Site.

We do not sell your personal information for monetary considerations. As discussed, we use cookies and other similar technologies and any potential future disclosures through such technologies could be deemed “sharing” for purposes of cross-context behavioral advertising under the CCPA. Some activities may constitute “targeted advertising” under other state privacy laws, such as the Connecticut Data Privacy Act, Colorado Privacy Act, and Virginia Consumer Data Protection Act.

 

VI. How We Use and Disclose Your Personal Information for a Business Purpose

TSG does not use or disclose any personal information about its Site users to any nonaffiliated third party, except as set forth below.

We may use or disclose for a business purpose certain personal information we collect about you as described in this Privacy Policy as part of our normal business operations, or to send you administrative communications either about your interactions with us, about features of the Site, or as part of our business communications.

We may also store your personal information and share it among our affiliates. We may use or disclose this information for marketing, research and other business purposes, and we may associate your personal information with other information we collect about you, such as details about your usage patterns and interests, but we will not sell this information or disclose it to third parties.

We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your personal information, as needed to perform their functions, but may not use it for another purpose.

We will use or disclose personal information when we believe that such disclosures are required by law, regulation, legal process, subpoena, document request or governmental request. For example, it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We may also do so to help enforce our Terms of Use or to protect the safety or security of our websites and other assets, our users (including you) and their property and the rights of third parties. Also, in the event that TSG or any of its assets or businesses are acquired or merged with another entity, whether an affiliate or a third party, user information (including personal information) may be one of the transferred assets.

 

VII. Governing Law and Forum

The laws of the State of California govern this Privacy Policy. Any dispute relating to this Privacy Policy or your use of the Site shall be resolved solely in the state or federal courts located in San Francisco County, California. You agree to waive trial by jury in any such action.

 

VIII. Data Subject Rights

We are committed to providing individuals with reasonable and appropriate access to their personal information. If you believe that we are processing personal information about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as where the request is manifestly unfounded or excessive. We are happy to correct inaccurate data or delete information that is not appropriate to retain. Please also let us know if you have any questions, concerns, disputes, or issues.

Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority. You can exercise these rights by contacting us at privacy@tsgconsumer.com. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

We do not discriminate against you, for example, by offering a different level of service, for exercising any of these rights.

If you make a request related to personal data about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. 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.

To exercise a data subject right, you should contact us using the contact information below.

 

IX. California Privacy Statement

If you are a resident of California, this California Privacy Statement, addressing our processing of personal information subject to the CCPA, will apply to you. Employees, contractors, and job applicants who are California residents receive a supplemental privacy notice that applies to their relationship with TSG in the context of their employment or job application. In the event of any conflict with this Privacy Policy, the terms of this supplementary statement will control.

In the past 12 months, we have collected the following categories and examples personal information from California residents.

 

Sensitive Personal Information.  Unless you intentionally supply it to us in an email, free text form, or otherwise, we do not collect Sensitive Personal Information on our Site or as otherwise described in this Privacy Policy.  If we receive Sensitive Personal Information, we use it for lawful purposes and do not use it to infer characteristics about you. Collection of Sensitive Personal Information from employees, investors or others is described in the separate privacy notices supplied to them.
Categories of Sources.
The categories of sources from which we collect Personal Information, as relevant to this Privacy Policy, are described in Section I above.

Business or Commercial Purposes for Collecting Personal Information. We use personal information for the business and commercial purposes disclosed in Sections I and VI above.

Sale or Sharing of Personal Information. We do not knowingly “sell” or “share” personal information as those terms are defined under the CCPA.

Retention of Personal Information. We will retain your Personal Information for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements, and for a reasonable time thereafter.

X. Miscellaneous

If any provision of this Privacy Policy is deemed unlawful, void, or for any reason unenforceable, that provision will be deemed severable from this Privacy Policy and will not affect the validity or enforceability of the remaining provisions.

XI. How to Contact Us

If you have any questions or comments about this Privacy Policy, or to exercise any of your data subject rights, you can email us at privacy@tsgconsumer.com, call us at 415-217-2300, fax us at 415-217-2350, or write to us at TSG Consumer Partners, LP, 1100 Larkspur Landing Circle, Suite 300 Larkspur, CA 94939.

Last updated: November 2023