Privacy Policy

Effective Date: May 2024

Last Updated: Feb, 2025

SCOPE

This Privacy Policy (“Policy”) describes how TWG Global, LLC, and affiliated investment, securities and other businesses of TWG Global, LLC including all subsidiaries of TWG Global, LLC (collectively, “TWG Global,” “we,” or “us”) treats personal information that we collect offline and through our websites and other online platforms where this Policy is located (collectively, our “Platform”). This Policy does not apply to our collection of employment-related information.

Certain affiliates of TWG Global have their own privacy policy with respect to their business or practices. Such policy will apply to information collected specifically by such entity only. Except as noted above, this Policy applies to anyone who visits or uses TWG Global’s websites where this Policy is posted or otherwise provides personal data to TWG Global in the course of business with TWG Global. Investors in funds are subject to separate privacy practices which are delivered to them on an annual basis pursuant to applicable laws. Depending on your location and the nature of your interactions with members of the TWG Global group, other members of the corporate group may act as data controllers in respect of your personal information (either in addition to or instead of the aforementioned entities). Please contact us if you would like further information about the members of the TWG Global corporate group that act as data controllers in respect of your personal information.

NOTICE AT COLLECTION

We collect information from you and about you. Here are some examples of the information we may collect, how we may use it, how we may disclose it and whether we share it for cross-contextual advertising purposes (“sharing”) or sell it. Below this Notice At Collection, you will find more detailed descriptions of how we may collect, use and disclose personal information.

Contact Information. This may include your name, mailing or billing address, email address, phone number, signature, physical characteristics or description. It may also include any other information you choose to provide when you contact us.

How We May Collect It : Directly from you or from third parties.

How We May Use It: To run and improve our business; to communicate with you and respond to your requests or questions; to understand your interests; to determine your eligibility; for marketing purposes; to combine information; for security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.

How We May Disclose It: Internally, including with affiliated entities; with our service providers; with our business partners; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.

We Do Not Share or Sell This Information.

Commercial information. This may include information that could identify you and relates to the services in which you are interested or have considered. We may also collect personal information about your consuming history or tendencies.

How We May Collect It: Directly from you; passively or from third parties.

We may share this information for cross-contextual marketing purposes. If you would like to learn about your right to opt out of this data sharing, please review the Your Privacy Rights section below.

Internet or other similar network activity. This may include unique personal identifier, online identifier, IP address, device identifier, browsing history, search history, and information regarding interaction with an Internet website, application, or advertisement. This may also include information about the browser you are using or what site you came from and what site you visit when you leave us. It may also include your general location based on your IP address.

How We May Collect It: Directly from you; passively or from third parties.

How We May Use It: To run and improve our business; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; to combine information; for security purposes; to comply with any procedures, laws, and regulations (including, without limitation, in relation to verification and “Know Your Customer” checks) which apply to us where it is necessary whether for our legitimate interests or the legitimate interests of others; as otherwise permitted by law or as we may notify you; as requested or directed by you.

How We May Disclose It: Internally, including with affiliated entities; with our service providers; with our business partners, including advertising networks; with any successors to all or part of our business; to comply with the law or to protect ourselves; for other reasons we may describe to you; as requested or directed by you.

Professional information. This may include your current or past job history, title, employer, salary information or professional contact information.

How We May Collect It: Directly from you or from third parties.

We Do Not Share or Sell This Information.

Inferences drawn from other personal information. This may include a profile relating to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitude. This may also include additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, social media platforms and other parties that we may attribute to you based on your assignment to certain statistical groups.

How We May Collect It: Directly from you; passively or from third parties.

How We May Use It: To run and improve our business; to supplement the information new have about you; to communicate with you; to understand your interests; to determine your eligibility; for marketing purposes; to combine information; for security purposes; as otherwise permitted by law or as we may notify you; as requested or directed by you.

Our Personal Information Retention Criteria: The California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”) requires that we disclose the criteria we use to determine how long we will retain each category of personal information we collect. Oftentimes, our records contain several of these categories of personal information combined together and therefore we consider, on a case-by-case basis, a number of factors to assess how long personal information is retained. These factors include what personal information is reasonably necessary to (i) provide our products and services or administer our relationship with an individual; (ii) protect our business, employees, organization and others; (iii) fulfill our legal and regulatory obligations; and (iv) investigate and address issues which may include safety concerns, potential security incidents or policy violations.

HOW WE MAY COLLECT YOUR PERSONAL INFORMATION

We may collect your personal information in different ways. Below, you will find additional details and examples regarding how we may collect your personal information.

Directly From You. For example:

Submit an inquiry or other information to us.

Sign-up for one of our events.

Request a demonstration.

Complete an online form.

Contact our sales or support team.

Interact with our social media pages.

Otherwise engage with us.

Passively. For example, when you visit and navigate our Platform on any device. We may also collect information about users over time and across different websites and devices when you use the Platform. We may use tools such as pixels, SDKs, and cookies, including tools run by third parties, to collect this information.

From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from:

Our business partners, including analytics vendors and advertising networks .

Social media sites, including Meta and LinkedIn.

Your contacts who provide your information to us because they think you may be interested in our products and services, or they want to share a product or service with you.

Companies that provide information to supplement what we already know about you, including data aggregators. Certain third parties may link your name and email address to other information they have collected. This might include online usage information.

HOW WE MAY USE YOUR PERSONAL INFORMATION

Here are more details and examples regarding how we may use your personal information:

To Run and Improve Our Business. We may use your information to make our Platform and our products and services better. This may also include using your information for business administration purposes, such as for accounting, record keeping, legal, backup and other administrative purposes.

To Communicate With You. This may include providing you with information that you request, to operate an internal database of our fans and to gather a profile of our fans, so we may better understand what interests you, and how we can better tailor our updates, responding to your feedback or providing customer support. It may also include responding to your inquiries and questions. We may communicate with you about your account or our relationship. We may also contact you about this Policy or our Platform terms and conditions.

To Understand Your Interests. This may include understanding what products and services may be of interest to you. This may also include customizing your experience with us.

To Determine Your Eligibility. This may include evaluating your eligibility for our products and services.

For Marketing Purposes. We may provide you with information about our company and our business initiatives, including through our newsletter. This includes using your information to personalize your experience on our Platform and with our products. We may also engage in cross-contextual advertising and retargeting.

To Combine Information. For example, we may combine information that we collect offline with information we collect through our Platform. We may also combine information we collect about you from the different devices you use to access our Platform.

For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.

As Otherwise Permitted By Law or As We May Notify You.

As Requested or Directed By You.

HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

Here are more details and examples regarding how we may disclose your personal information:

Internally. We may disclose your information to our parent, subsidiary, and affiliate entities.

On Our Platform. For example, we may disclose your information on our Platform or on our social media sites.

With Our Service Providers. We may disclose your information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Platform.

With Our Business Partners. For example, we may also disclose personal information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Policy. We may also disclose personal information with companies that help us learn more about our customers.

With Any Successors to All or Part of Our Business. For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization or other change of control.

To Comply With the Law or To Protect Ourselves. For example, this could include responding to a court order or subpoena. It could also include sharing information if a government agency or investigatory body requests. We might disclose information when we are investigating a potential fraud.

For Other Reasons We May Describe to You.

As Requested or Directed By You.

YOUR PRIVACY RIGHTS

Based on your state or country of residence, you may have the rights listed below with respect to the personal information that we maintain about you. We may take steps to verify your identity, as permitted or required under applicable law, before we process your request. Verification may include asking you to provide information about yourself that we can match against information already in our possession.

Please note that we do not knowingly sell or share the personal information of consumers under 16 years.

Notice. This means that you can request that we disclose what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, and the categories of third parties to whom we have disclosed personal information.

Access. This means that you can request that we provide access to and/or a copy of certain information we hold about you.

Deletion. This means that you can request that we delete personal information about you which we have collected from you.

Correction. This means that you can request that we correct inaccurate personal information that we maintain about you.

Opt-Out of Sale of Personal Information. If you would like to opt out of allowing us to “sell” your personal information, please follow the instructions below. As of the date of this policy, we do not, and for the past 12-months have not, “sold” personal information.

Opt-Out of Sharing of Personal Information. You may have the right to opt out of sharing of personal information with third parties for cross-contextual marketing purposes. If you would like to limit the cookies and other tracking tools used on our Platform, in addition to submitting a request below, you will need to disable cookies as described in the Cookies and Other Tracking Technologies above. Please note that the choices you make may be browser- and device-specific, and your choices may be deleted if you clear your browser cache or cookies.

Limit Certain Processing Activities. This means that you can request that we limit or stop the processing of your information for certain purposes (including for the purpose of direct marketing).

Limit the Use or Disclosure of Sensitive Personal Information. Some laws classify certain personal information as sensitive personal information. If you are a California resident, you may have the right to request that we limit the use or disclosure of this sensitive personal information. In certain states, if you gave us consent to process this sensitive personal information, you may have the right to revoke this consent. If you submit a request, please note that this does not impact how we use or disclose your sensitive personal information prior to processing your request.

Right to Non-Discrimination. This means that we are prohibited from discriminating against you if you exercise your rights under applicable law.

If you wish to exercise your rights under this section, you can contact us at [email protected]. Please include your name, email address, and state of residence, and indicate you are making a “Privacy Rights” request. If we deny your rights request and you would like to appeal, you may contact us at [email protected]. You also have the right to make a complaint to the local supervisory authority in your state or country.

Agents. Agents that you have authorized to act on your behalf may also submit privacy requests as instructed above. The agent must also provide evidence that they have your permission to submit a request on your behalf. If we are unable to verify the authenticity of a request, we may ask you for more information or may deny the request.

Additional Information for California Residents. If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at [email protected]. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.

CHILDREN UNDER 16

Our Platform is intended for general audiences and not for children under the age of 16. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, or from children under the age of 16, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU or UK residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU or UK resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

COOKIES AND ELECTRONIC COMMUNICATIONS

You have certain choices about how we collect, use and disclose your information in connection with our use of cookies and our provision of electronic communications. Certain choices you make are browser and device specific.

Cookies & Other Tracking Technologies:

Cookies: You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.

Google Analytics: We may use Google Analytics on our Platform to help us understand how you use our Platform. You can learn about how to opt-out of Google Analytics here.

Social Media: We may use cookies or pixels from social media platforms to help us understand how you use our Platform or to target ads to you. For example, these may include cookies or pixels from Meta and LinkedIn. For more information about how to control tracking from these platforms, please click the provided links.

Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.

Note that deleting or blocking cookies may impact your experience on our website, as some features may not be available. Certain options you select are browser and device specific.

Our Do Not Track Policy: Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to “do not track” signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.

Marketing Communications:

You can opt out of receiving our marketing communications, which we may send by email. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

SECURITY

TWG Global takes technical and organizational security measures to protect the information provided via the websites from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to TWG Global via the Internet.

STORAGE AND TRANSFER OF INFORMATION

Your information will be processed for the purposes described herein. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within TWG Global and its affiliates, service providers, and business partners in other countries (including countries outside of the United States, the UK and the EEA), in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of the website to you and the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to third party information processors, we will take appropriate measures to ensure such companies protect your information adequately and in accordance with applicable law. These measures may include entering into an appropriate data transfer mechanism in accordance with EU, UK and/or other data protection laws to govern the transfers of such data.

LINKS

Our Platform may contain links to third-party websites such as social media sites. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties.

HOW TO CONTACT US

Please feel free to contact us if you have any questions about this Policy or our information practices. You can reach us via email at [email protected].

CHANGES IN POLICY

We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our websites, or advances in technology. We will make the revised Policy accessible through the websites, so you should review the Policy periodically. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the websites, you are confirming that you have read and understood the latest version of this Policy.