Effective January 1, 2023
If you are a Roark investor or a representative of an investor, please see our Investor Privacy Notice, which is available in our investor portal, for additional information about our collection, use, and sharing practices with respect to investor information. In addition, our investor portal provider’s policies also apply to the information collected in our investor portal.
Table of Contents
- Personal Information We Collect
- Sources from Which We Collect Personal Information
- Our Purposes for Collecting Personal Information
- How Long We Keep Your Personal Information
- Our Disclosures of Personal Information
- Additional Information for California Residents
- Virginia Privacy Rights
- Nevada Privacy Rights
- Cookies and Other Tracking Technologies
- Children’s Privacy
- International Visitors
- Third-Party Links and Services
- Changes to this Policy
- How to Contact Us
1. Personal Information We Collect
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.
The Personal Information we collect about you may vary depending on the nature of your interactions with us. In general, we collect the following categories of Personal Information:
- Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers
- Personal information described in Cal. Civ. Code § 1798.80(e), including name, signature, social security number, physical characteristics or description, 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 other financial information, medical information, or health insurance information
- Characteristics of protected classifications, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, marital status
- Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
- Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements
- Audio, electronic, visual, thermal, olfactory, or similar information, including photographs and video, and audio recordings as may relate to job functions or interactions with Roark via phone or videoconferencing
- Geolocation Data, inferred from your IP address
- Professional or employment-related information
- Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your education
- Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
- Sensitive Personal Information, including the following categories of Sensitive Personal Information:
- Personal Information that reveals a Social Security, driver’s license, state identification card, or passport number
- Personal Information that reveals an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
- Personal Information that reveals racial or ethnic origin, religious or philosophical beliefs, or union membership
- Personal Information collected and analyzed concerning health
- Personal Information collected and analyzed concerning sexual orientation
2. Sources from Which We Collect Personal Information
Generally, we collect the categories of Personal Information described above from the following categories of sources:
- Directly from you
- From our affiliates, subsidiaries, and portfolio companies
- Automatically when you use our website
- Within the context of due diligence for potential acquisitions
- From service providers that help us to operate our business (e.g., vendors that provide communications, market research, analytics, customer support, and other services)
- From internet service providers, data analytics providers, advertising networks, social networks, and third parties from which we may license or otherwise purchase data
- Created by us (e.g., drawing inferences from the other categories of Personal Information we collect or assigning a username or email address to an employee)
3. Our Purposes for Collecting Personal Information
Generally, we use the Personal Information we collect for the following purposes. The specific purposes for which we collect your Personal Information may vary depending on the nature of your relationship with us.
- To provide our Services
- To communicate with you
- To provide and improve our investment services, including evaluating potential investments and managing existing investments. (Please see our Investor Privacy Notice for additional information.)
- To analyze trends and improve our Services
- To provide analytics, financial analysis, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services pursuant to agreements with our portfolio companies
- For promotions, marketing, and events
- For recruiting and employment purposes, including opening and maintaining application records, assessing eligibility for employment, onboarding employees, providing compensation and benefits, allowing you to perform your job functions, and managing our workforce.
- To manage the security of our systems, property, website, and Services
- To manage and support our IT resources and infrastructure
- To comply with applicable laws and regulations
- To detect, investigate, and protect against malicious, deceptive, fraudulent, or illegal activity
We may use the categories of Sensitive Personal Information we collect to comply with government reporting requirements and other legal obligations, for security and fraud-prevention, and for employee onboarding, benefits and accommodations.
In addition to the purposes described above, we may use and disclose any category of Personal Information or Sensitive Personal Information we collect to respond to law enforcement requests, or as otherwise required or authorized by applicable law, court order, or governmental regulations; to protect our rights and interests and those of others; to resolve any disputes; to enforce our terms and policies; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our assets. We also reserve the right to use Personal Information we collect for any other purpose identified in an applicable privacy notice or agreement between you and us, or otherwise with your consent.
4. How Long We Keep Your Personal Information
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:
- Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
- The Personal Information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires.For more information about our retention policies, please contact us using the contact details provided below.
5. Our Disclosures of Personal Information
We share Personal Information with our service providers and contractors for the following business and commercial purposes:
Categories of Personal Information
Purposes for Disclosure
Characteristics of protected classifications
Internet or other electronic network activity information
Professional or employment-related information
Non-public education information
Social security, driver’s license, state identification card, or passport number
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
Personal Information collected and analyzed concerning health
In addition to the above, we may disclose Identifiers, Personal Information described in Cal. Civ. Code § 1798.80(e), Characteristics of protected classifications, Commercial information, and Inferences to our portfolio companies to provide analytics, financial analysis, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services.
6. Additional Information for California Residents
Sales and Sharing of Personal Information
Although we do not sell Personal Information in exchange for money, some of the ways in which we share Personal Information among our portfolio companies may be considered “sales” under the CCPA. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age. The categories of Personal Information we “sell” or “share” (as those terms are defined under the CCPA) are as follows: Identifiers, Personal Information described in Cal. Civ. Code § 1798.80(e), Characteristics of protected classifications, Commercial information, and Inferences.
California Privacy Rights
If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request through our webform or call us at 1-833-508-0401. Please note that, if you submit a request to know, request to delete, or request to correct, you will be asked to provide 2-3 pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. An authorized agent may submit a request on your behalf using the webform or toll-free number listed above.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
- The categories of Personal Information we have collected about you, including
- The categories of sources from which the Personal Information was collected
- Our business or commercial purposes for collecting, selling, or sharing Personal Information
- The categories of recipients to which we disclose Personal Information
- The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
- The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
- The specific pieces of Personal Information we have collected about you
Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out, please submit a request through our webform. Our website is configured to recognize the Global Privacy Control (GPC) browser signal; however, because we are generally unable to connect website visitors to other information we collect, we require additional information from you in order to opt you out of “sales” of Personal Information relating to our processing of Personal Information made available to us by our portfolio companies. If you would like to opt out of those types of “sales” of Personal Information, please submit a request using our webform.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
7. Virginia Privacy Rights
Right to Access and Data Portability. You have the right to confirm whether we are processing your Personal Information, to access your Personal Information, and to obtain a copy of Personal Information you provided to us in a portable format.
Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes for processing it.
Right to Delete. You have the right to request that we delete your Personal Information.
Right to Opt Out. You have the right to opt out of the following uses of your Personal Information: (a) targeted advertising; (b) the sale of Personal Information; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects. Because Roark does not engage in targeted advertising, sell personal information (as defined under the VCDPA), or engage in profiling, you do not need to submit an opt-out request to us.
Right to Appeal. Sometimes we are unable to process requests relating to your Personal Information, in which case, your request will be denied. If you are a resident of Virginia whose privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request using our webform.
Please note that if you make a privacy rights request, we will retain a record of your request for recordkeeping purposes.
8. Nevada Privacy Rights
Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, telephone number, email address, and other information through which a person may be contacted. Our uses of your personal information are not sales under Nevada law. If you have any questions or if you would like to receive notice by email in the event we should engage in “sales” of personal information under Nevada law in the future, please contact us using the contact information provided below or by using our webform.
9. Cookies and Other Tracking Technologies
Do Not Track (“DNT”) is a privacy preference signal that users can set in certain web browsers. We do not currently recognize or respond to DNT signals.
10. Children’s Privacy
Our Services are neither intended for, nor targeted to those under 16. If we learn that we possess information from a child under the age of 16, we will delete such information in accordance with applicable laws.
We take commercially reasonable measures to protect Personal Information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure, so we cannot guarantee the security of information collected through the Services.
12. International Visitors
13. Third-Party Links and Services
14. Changes to this Policy
15. How to Contact Us
If you have any questions about how Roark handles your Personal Information or if you need to access this Policy in an alternative format due to a disability, please contact us at email@example.com.