This privacy policy for California residents (this “California Privacy Notice”) is provided in addition to the information in any other privacy notice provided by Quad, and explains Quad’s online and offline collection, use, and disclosure of Personal Information relating to residents of the State of California (“consumers”, “you” or “your”) covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, together with any applicable regulations (all together, the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this California Privacy Notice. This California Privacy Notice is available in alternative formats upon request. Please contact Linda Diaz by telephone at (212)724-2200 and by e-mail at linda@quadpartners.com to request this California Privacy Notice in an alternative format.
This California Privacy Notice applies solely to California residents and does not apply to information collected, processed or disclosed by Quad pursuant to the Gramm-Leach-Bliley Act and its implementing regulations, or the California Financial Information Privacy Act. We may amend this California Privacy Notice from time to time, and will provide you with such amendments in the same manner in which you have received this form.
1. NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION
a. Collection of Personal Information.
We may collect the following categories of Personal Information about you and our other investors online and/or offline when you become an investor, as well as in the course of administering our investment program:
- Identifiers, including your name and contact details (i.e. home and email address, home and mobile phone numbers), social security number, passport number, unique personal identifier (e.g., device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology), online identifier, internet protocol address, and other similar identifiers;
- Records Subject to California Law (Cal. Civ. Code § 1798.80), including your signature, physical characteristics or description, state identification card (including driver’s license) number, education information, information obtained as a result of your investment in any of our funds (such as advisor details, investment details, banking details, and financial details), as well as banking information, tax information, social security number or other tax identification number and details of tax residency, and other financial information;
- Protected Classifications, including under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, immigration or citizenship status, and military and veteran status;
- Commercial Information, including your investment information, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies, as well as data about your capital account, capital contributions, profit and loss allocations and distributions and withdrawals from our funds, as well as information about other transactions with us, our affiliates or others, such as participation in our investment programs or products;
- Online Activity, including your Internet and other electronic network activity and usage information (e.g., browser type, operating system, browsing history, search history, and information regarding your interaction with websites, applications or advertisements);
- Employment Information, including your professional or employment-related information (e.g., experience, qualifications and employment history);
- Inferences; including 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;
- Sensitive Personal Information, including social security number, driver’s license number, or passport number, account credentials (e.g., account and password), as well as contents of a consumer’s mail, email and text messages; and
- Other information you create or provide to us, including the content of your communications with us and/or with our representatives, service providers and affiliates, including in-person discussions, telephone conversations, and electronic or other communications.
We do not knowingly collect or solicit any categories of Personal Information from any individual under the age of eighteen (18).
b. Business Purposes for which we use Personal Information.
We may use certain categories of Personal Information for the business purposes described below.
Categories of Personal Information
Performing and providing the services that Quad offers.
Identifiers; Records Subject to California Law; Commercial Information; Online Activity; Employment Information; and Inferences.
Communicate with you about the services Quad offers, respond to your questions or offer you additional products or services.
Identifiers; Commercial Information; Online Activity; Other information you create or provide to us.
Auditing related to a current interaction with you and concurrent transactions.
Identifiers; Records Subject to California Law; Commercial Information; Online Activity; Employment Information; and Inferences.
Short-term, transient uses.
Identifiers; Online Activity; and Inferences.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (including to protect our assets and to investigate or defend against any claims of illegality or wrongdoing or in response to a court order or judicial or other government subpoena or warrant).
Identifiers; Customer Records to Subject California Law; Commercial Information; Online Activity; Employment Information; and Inferences.
Managing our website (e.g., enable, analyze and improve our website, authenticate you, track pages viewed or messages opened, to personalize your browsing experience, and to provide you with tailored content), and debugging to identify and repair errors that impair existing intended functionality.
Identifiers; Online Activity; and Inferences.
Undertaking internal research for technological development and demonstration.
Identifiers; Customer Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
Undertaking activities to verify or maintain the quality of our services, including but not limited to managing and mitigating risk, assessing compliance with applicable laws, legal requirements, and our policies (including to maintain the privacy and security of our data), protect our assets, conducting internal audits or investigations, obtaining legal advice or to establish, exercise or defend legal rights, and conducting anti-money laundering (AML) and Know Your Customer (KYC) reviews.
Identifiers; Customer Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences.
Engaging in corporate or business transactions, including any prospective merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event.
Identifiers, Customer Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Employment Information; Inferences; Sensitive Personal Information; Other information you create or provide to us.
Recruiting or hiring personnel.
Identifiers, Customer Records Subject to California Law; Protected Classifications; Employment Information; Inferences; Sensitive Personal Information; Other information you create or provide to us.
c. Retention of Personal Information.
We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected or to comply with the law, prevent fraud, facilitate an investigation, defend against legal claims, or exercise our legal rights.
We determine the period for retaining your personal information with regard to the period for which storage is necessary to achieve the purpose for collecting the information, and our operational and legal requirements (which includes responding to legal claims or regulatory requests).
For example, although there may be some limited exceptions, in general we will retain your personal information for at least 5 years after you have terminated your relationship with Quad and its affiliates. Subject to legal and regulatory requirements, this data is then retained in accordance with Quad’s backup retention policy. Where there are technical limitations that prevent deletion or anonymization in backup, we safeguard personal data through access control measures to limit the active use of it.
2. OUR PRIOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
We may have collected and used your Personal Information, as described in Section 1 during the 12-month period prior to the “lasted updated’ date of this California Privacy Policy. For the Personal Information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the Personal Information (b) the categories of recipients to whom we may have disclosed Personal Information for a business purpose, and (c) any categories of Personal Information sold to third parties and shared for cross-context behavioral advertising purposes.
a. Sources of Personal Information.
We may have obtained Personal Information about you from various sources, as described below.
Categories of Sources of Data Collection
Categories of Personal Information
Directly from you, including, for example, through subscription materials and other forms, when you send us an email, visit our premises, or otherwise contact or communicate with us.
Identifiers; Records Subject to California Law; Protected Classifications; Online Activity; Employment Information; and Inferences.
From automatic tracking technology and monitoring tools, such as cookies that track your access and use of our websites and other online services.
Identifiers; Records Subject to California Law; Protected Classifications; Online Activity; and Inferences.
From our affiliates and/or entities owned or controlled by Quad.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
From counterparties and intermediaries (e.g., broker- dealers).
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
From businesses that we are evaluating in connection with a potential investment or business opportunity.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
From vendors (e.g., background check providers), advisors and other business partners.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
From recruiting agencies, social media networks or publicly available sources.
Identifiers; Records Subject to California Law; Protected Classifications; Employment Information; and Inferences.
From service providers, including, but not limited to the fund administrators, brokers, contractors, or third parties responsible for conducting identity verification or anti-money-laundering checks on prospective investors.
Identifiers; Records Subject to California Law; Protected Classifications; Employment Information; and Inferences.
b. Disclosures of Personal Information for Business Purposes.
We may have disclosed your Personal Information to certain categories of recipients for the business purposes identified in the chart below.
Business Purposes
Categories of Recipients
Categories of Personal Information
Performing services.
Group companies and affiliates; service providers, contractors and other vendors, broker-dealers, advisors and others who provide services to us or on our behalf (together, “service providers and contractors”); professional services organizations, such as auditors, tax advisors and law firms (together, “professional advisors”; prospective lenders to or creditors of an entity in which we have or are considering investing.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences.
Auditing related to a current interaction with you and concurrent transactions.
Group companies and affiliates; service providers and contractors; professional advisors; and prospective lenders to or creditors of an entity company in which we have or are considering investing.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
Short-term, transient use.
Service providers and contractors.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
Group companies and affiliates; Service providers and contractors; government entities, including regulatory agencies and law enforcement; and professional advisors.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
Debugging to identify and repair errors that impair existing intended functionality.
Service providers and contractors.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Employment Information; and Inferences.
Undertaking internal research for technological development and demonstration.
Group companies and affiliates; service providers and contractors; recruiting agencies, social media networks or publicly available sources and professional advisors.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences.
Undertaking activities to verify or maintain the quality of our services.
Group companies and affiliates; service providers and contractors; government entities, including regulatory agencies and law enforcement; and professional advisors.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences.
To (a) comply with legal obligations such as in connection with a valid court order, judicial subpoena or regulatory inquiry; and as required by law enforcement agencies, federal or state regulatory agencies, or self-regulatory organizations and (b) conduct anti-money laundering (AML) and Know Your Customer (KYC) reviews.
Group companies and affiliates; government entities, including regulatory agencies and law enforcement; and professional advisors.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences.
In the event we undertake or are involved in or contemplate any merger, acquisition, reorganization, or sale of assets, or a bankruptcy or insolvency event.
Group companies and affiliates; service providers and contractors; government entities, including regulatory agencies and law enforcement; professional advisors; prospective lenders to or creditors of an entity in which we have or are considering investing; and prospective business partners or purchasers.
Identifiers; Records Subject to California Law; Protected Classifications; Commercial Information; Online Activity; Employment Information; and Inferences.
Quad may share anonymous or aggregated data in order to facilitate our business operations. To the extent such data constitutes anonymized or de-identified data under the CCPA and other applicable privacy and data protection laws, we will maintain and use such data without attempting to re-identify the data.
We do not use computer algorithms to make automated decisions based on your Personal Information. We may process some of your Personal Information automatically, with the goal of assessing certain personal aspects (profiling), such as to comply with legal or regulatory obligations such as to combat money laundering or terrorism financing.
c. Sale and/or Sharing of Personal Information.
- Sales of Personal Information. Under the CCPA, a sale of Personal Information is any disclosure to a third party other than our service providers or contractors for monetary gain or any other valuable benefit. Quad has not engaged in any such sales of Personal Information in the preceding twelve (12) months, including with respect to minors under sixteen (16).
- Sharing Personal Information for cross-context behavioral advertising. Cross-context behavioral advertising involves the tracking of an individual's activities across websites, applications, and services to identify and present advertisements tailored to their behavior. In the preceding twelve (12) months, we have not shared any Personal Information with third parties for purposes of cross-context behavioral advertising.
d. Sensitive Personal Information.
To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business (i.e. customer service); (vii) to verify and maintain the quality of our services; and (viii) generally for purposes that do not infer characteristics about you.
3. HOW WE PROTECT YOUR PERSONAL INFORMATION
Quad has implemented and maintains commercially reasonable and appropriate technical and organizational measures designed to protect the confidentiality, integrity, and security of your Personal Information. Client files are protected with safeguards according to the sensitivity of the information contained therein. Controls such as restricted access are placed on our computer systems and used where appropriate. Reasonable measures are taken to ensure physical access to Personal Information is limited to authorized employees.
As a condition of employment, our employees are required to follow applicable laws and regulations, including in relation to data protection and privacy laws. Unauthorized use or disclosure of confidential client information by a Quad employee is prohibited and may result in disciplinary measures.
When you contact a Quad employee about your file, you may be asked to confirm some details relating to the Personal Information we hold about you. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.
4. CALIFORNIA CONSUMER PRIVACY RIGHTS
a. Your CCPA Privacy Rights.
You have certain choices regarding our use and disclosure of your Personal Information, as described below.
- Know: You have the right to request, twice in a 12-month period, that we provide certain information about the (i) the categories of Personal Information we have collected about you; (ii) the categories of sources from which the Personal Information is collected; (iii) the business or commercial purpose for collecting your Personal Information; and (iv) the categories of third parties with whom we have shared your Personal Information; and (v) that we disclose to you the specific pieces of Personal Information we have collected, used, and disclosed about you during the past 12 months.
- Deletion: You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
- Correction: You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate.
- Limit: You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. To the extent we collect any sensitive personal information from or about you, we use it only for purposes listed above in Section 1(b). As such, any sensitive personal data that we collect does not come within this right to limit use.
- Opt-out: You have the right to request that we opt-out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for certain purposes.
- Non-Discrimination: You have the right to not to experience discriminatory and we will not discriminate against you because you have exercised any California consumer privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
b. How to Submit a Request.
If you are a California resident and you wish to exercise any of the rights enumerated in this Section 3, please contact us at (212)724-2200 or by e-mail at linda@quadpartners.com.
c. Verifying Your 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 we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
- Verification Process. If you request to know, access, delete, and/or correct your Personal Information, we may require you to provide any of the following information: address, date of birth, unique personal identifier, nationality, telephone number, email address, CV information or details of a transaction. In addition, if you ask us to provide you with specific pieces of Personal Information, we may require you to sign a declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.
- Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission to do so (e.g., via a notarized letter), and (2) verify your own identity directly with us (as described above) and confirm with us that you provided the authorized agent permission to submit the request.
d. Additional California Privacy Disclosures
- Do Not Track Signals. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals.
- Shine the Light Notice. California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided Section 4(b), above.