HGGC

Last Updated: October 2024

Terms of Use

These Terms of Use constitute a legally binding agreement between HGGC, LLC (“Adviser”) and its affiliates (together, “Adviser,” “our,” “us,” “we,” or “company”) and you, the user of https://www.hggc.com/ (the “Website”). By accessing the Website you acknowledge that you have read and agree to these Terms of Use. These Terms of Use govern your use of the Website. Please read these Terms of Use carefully. If you do not agree with any of the terms and conditions contained herein, please do not access the Website.

Adviser reserves the right to amend these Terms of Use in its sole discretion. Adviser will post any changes to these Terms of Use on the Website, and changes are effective immediately upon posting. Your continued use of the Website after any such changes constitutes your acceptance of the new terms and conditions. You should consult the “Terms of Use” bar on the Website each time you visit the Website.

The Website is offered and available to users who are 18 years of age or older. By using the Website, you represent and warrant that you are of legal age to form a binding contract with Adviser. If you do not meet all of these requirements, you must not access or use the Website.

PURPOSE OF THE WEBSITE; NOT INVESTMENT ADVICE; NO RECOMMENDATIONS

The information presented on or through the Website is made available solely for informational purposes in relation to Adviser and its financing capabilities for prospective portfolio companies. Adviser does not warrant the accuracy, completeness, or usefulness of any information on the Website. Any reliance you place on such information is strictly at your own risk. Adviser disclaims all liability and responsibility arising from any reliance placed on such materials by you or any other visitor to the Website, or by anyone who may be informed of any of its contents.

This Website is not intended to provide legal, business, tax, accounting, investment, or other advice. You agree not to construe any of the Content (as defined below) provided in connection with the Website as legal, business, tax, accounting, investment, financial, or other advice. You agree that the Content provided in connection with the Website does not, and shall not be deemed to, constitute an offer to sell, or a solicitation to any person to buy, any security or other investment. You understand that none of the Content constitutes a recommendation that you or any other person purchase, sell, or hold any security, company, investment product, or other investment, or that you should pursue any investment strategy, and the Content is not to be relied upon for the purpose of making investment or other decisions. In addition, you understand and agree that all Content provided in connection with the Website is published without consideration of your individual circumstances, financial or otherwise. Accordingly, you agree that you are solely responsible for any investment decisions or other determinations made, including the evaluation of any investment or other risks, with respect to any of the Content provided in connection with the Website. You agree to consult your own professional advisors as to any legal, business, tax, accounting, investment, financial, or other advice regarding any Content provided in connection with the Website.

REGULATORY DISCLOSURES

Adviser does not solicit or make its services available to the public. The Content provided on or through the Website may include information regarding past and/or present portfolio companies or investments managed by Adviser, its affiliates, and/or its personnel. It should not be assumed that investments made in the future will be comparable in quality or performance to the investments described herein. Further, references to past and present portfolio companies should not be construed as a recommendation of any particular investment or security. Current and previous portfolio companies listed on the Website are not to be considered a complete list of all investments historically made by Adviser. The portfolio companies listed should not be assumed to have been profitable. Any past performance information on the Website is not necessarily indicative, or a guarantee, of future results.

Certain information contained on the Website constitutes “forward-looking statements.” All forward-looking statements represent only the intent and belief of Adviser as of the date such statements were made. None of Adviser or any of its affiliates (i) assumes any responsibility for the accuracy and completeness of any forward-looking statements or (ii) undertakes any obligation to disseminate any updates or revisions to any forward-looking statement contained on the Website to reflect any change in their expectation with regard thereto or any change in events, conditions, or circumstances on which any such statement is based. Due to various risks and uncertainties, actual events or results may differ materially from those reflected or contemplated in such forward-looking statements.

PRIVACY POLICIES

In addition to these Terms of Use, your use of and access to the Website is also subject to our Website Privacy Policy (the “Privacy Policy”), our California Privacy Policy (the “California Privacy Policy”), and our EU-UK Privacy Notice Supplement (the “EU and UK Privacy Notice Supplement”), which are incorporated by reference herein, as applicable and to the extent permitted by applicable law. Our Privacy Policy, our California Privacy Policy, and our EU Privacy Policy contain additional terms relating to our potential collection, use, and disclosure of your personal information, as applicable. You agree that you have read, agreed to, and understand our privacy policies, as applicable.

CONFIDENTIALITY

If you choose, or are provided with, a user name, password, or any other piece of information as part of Adviser’s security procedures, you must treat such information as confidential, and you must not disclose it to any other person or entity. You also acknowledge that your account is personal to you and agree not to provide any other person with access to this Website or portions of it using your user name, password, or other security information. You agree to notify Adviser immediately of any unauthorized access to or use of your user name or password or any other breach of security. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing your account from a public or shared computer so that others are not able to view or record your password or other personal information.

Adviser has the right to disable any user, whether chosen by you or provided by us, at any time in Adviser’s sole discretion for any or no reason, including if, in Adviser’s opinion, you have violated any provision of these Terms of Use.

OWNERSHIP

The trade names, trademarks, service marks, trade dress, logos, and other indicia of source (collectively, “Marks”) found on the Website and any and all information and content available through the Website (including strategies, policies, business plans, research, concepts, and other information (collectively, the “Content”) are proprietary to Adviser or its licensors and are protected by intellectual property rights and unfair competition and other laws. You may not use any Mark or Content without the express written permission of the owner (whether Adviser or otherwise), and nothing contained in these Terms of Use or anywhere on the Website shall be construed as granting any license or right to use any Mark or Content.

THIRD-PARTY LINKS

From time to time, Adviser may provide links from this Website to websites operated by third parties. Adviser’s decision to do so is in no way an endorsement of these sites. Adviser does not monitor, edit, or control such third-party sites and is not responsible in any way for the suitability of their content or for the quality of the products or services offered therein. Your choice to follow links to such websites is at your sole risk. If you have any questions regarding a linked site, please direct them to the administrator of the relevant site. Adviser reserves the right to terminate any link at any time.

DISCLAIMER OF WARRANTIES

THE WEBSITE AND CONTENT ARE PROVIDED “AS IS” AND “AS AVAILABLE” AND, TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW, PROVIDED WITHOUT WARRANTIES, CLAIMS, OR REPRESENTATIONS MADE BY ADVISER, EITHER EXPRESS, IMPLIED, OR STATUTORY, WITH RESPECT TO THE WEBSITE, INCLUDING WARRANTIES OF QUALITY, PERFORMANCE, NON-INFRINGEMENT, MERCHANTABILITY, OR FITNESS FOR A PARTICULAR PURPOSE, NOR ARE THERE ANY WARRANTIES CREATED BY COURSE OF DEALING, COURSE OF PERFORMANCE, OR TRADE USAGE. ADVISER FURTHER DOES NOT REPRESENT OR WARRANT THAT THE WEBSITE OR CONTENT WILL ALWAYS BE AVAILABLE, ACCESSIBLE, UNINTERRUPTED, TIMELY, SECURE, ACCURATE, COMPLETE, OR ERROR-FREE. YOU ACKNOWLEDGE THAT THE ENTIRE RISK ARISING OUT OF THE USE OR PERFORMANCE OF THE WEBSITE REMAINS WITH YOU TO THE MAXIMUM EXTENT PERMITTED UNDER APPLICABLE LAW.

LIMITATION OF LIABILITY

ADVISER DOES NOT ASSUME ANY LIABILITY OR RESPONSIBILITY FOR THE WEBSITE OR THE CONTENT. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, ADVISER IS NOT LIABLE TO YOU OR ANYONE ELSE FOR ANY CLAIM OF ANY NATURE WHATSOEVER BASED ON (1) THE WEBSITE OR THE CONTENT, INCLUDING ANY DECISION MADE OR ACTION TAKEN IN RELIANCE ON THE CONTENT OR ANY FEATURE OF THE WEBSITE, OR (2) YOUR BREACH OF ANY PROVISION OF THESE TERMS OF USE.

UNDER NO CIRCUMSTANCES WILL ADVISER BE LIABLE FOR ANY DAMAGES OR LOSSES (INCLUDING DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES, LOST REVENUES, LOST PROFITS, LOSS OF BUSINESS, LOSS OF DATA, OR ANY OTHER DAMAGES OR LOSSES) ARISING OUT OF OR IN CONNECTION WITH THESE TERMS OF USE OR YOUR USE OF ANY SERVICE OR CONTENT, REGARDLESS OF THE THEORY OF LIABILITY, WHETHER TORT (INCLUDING NEGLIGENCE OF ANY KIND), CONTRACT, OR ANY OTHER LEGAL OR EQUITABLE THEORY, EVEN IF ADVISED OF THE POSSIBILITY OF THE DAMAGES OR IF THE DAMAGES COULD HAVE BEEN FORESEEN.

THE FOREGOING DOES NOT AFFECT ANY LIABILITY THAT CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW.

INDEMNITY

You agree that you will be solely responsible for, and that you will defend, indemnify and hold Adviser, its parents, subsidiaries, and other affiliates and each of their respective officers, directors, agents, employees, and representatives harmless from and against any and all claims, demands, liabilities, costs, or expenses, including reasonable attorneys’ fees, resulting from your violation of these Terms of Use or otherwise resulting from your use of the Website. Adviser reserves the right, at its own expense, to assume the exclusive defense and control of any matter for which it is entitled to indemnification, but you must still indemnify Adviser for all liabilities, losses, or damages. You agree to provide Adviser with whatever cooperation it reasonably requests.

LIMITATION ON TIME TO FILE CLAIMS

ANY CAUSE OF ACTION OR CLAIM YOU MAY HAVE ARISING OUT OF OR RELATING TO THESE TERMS OF USE OR THE WEBSITE MUST BE COMMENCED WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES, OTHERWISE, SUCH CAUSE OF ACTION OR CLAIM IS PERMANENTLY BARRED, UNLESS OTHERWISE REQUIRED BY APPLICABLE LAW.

MISCELLANEOUS

You may not assign or otherwise transfer these Terms of Use or your rights or obligations under it without Adviser’s prior written consent, and any attempted assignment or other transfer in violation of this provision shall be null and void. Adviser may assign these Terms of Use or any rights under these Terms of Use without your consent and without notice. Nothing in these Terms of Use may be used to construe you and Adviser as joint venturers, co-employers, partners, or agents of each other, and neither you nor Adviser has the power to obligate or bind the other in any way whatsoever. Should any term or provision hereof be deemed invalid, void or unenforceable either in its entirety or in a particular application, the remainder of these Terms of Use shall nonetheless remain in full force and effect. The failure of Adviser at any time or times to require performance of any provision hereof shall in no manner affect its right at a later time to enforce the same unless the same is waived in writing. These Terms of Use shall be governed by and construed in accordance with the laws of the State of Delaware without regard to its conflict of law rules. Any legal proceeding arising out of or relating to these Terms of Use against or relating to Adviser or any indemnified party under these Terms of Use will be subject to the exclusive jurisdiction of any state or federal court sitting in the State of Delaware, and you irrevocably consent to the jurisdiction of such courts. The terms and conditions set forth in these Terms of Use and any agreements included or referred to in these Terms of Use constitute the final, complete, and exclusive agreement with respect to the Website and may not be contradicted, explained, or supplemented by evidence of any prior agreement, any contemporaneous oral agreement, or any consistent additional terms.

Headings and captions throughout these Terms of Use are for convenience only and should not be considered part of these Terms of Use. The word “including” means “including without limitation.”

If you have any questions or concerns about these Terms of Use or any issues raised in these Terms of Use or on the Website, please contact Adviser at compliance@hggc.com.

Website Privacy Notice

LAST UPDATED: October 2024

OUR COMMITMENT TO PRIVACY

Your privacy is important to HGGC, LLC and its affiliates (together, “HGGC”, “our”, “us”, “we”, or “company”). To better protect your privacy, we are providing information explaining our online information practices.

This Website Privacy Notice (this “Privacy Notice”) describes how we gather and use information for visitors of this website. Please read this Privacy Notice carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use this website.

This Privacy Notice constitutes a legally binding agreement between HGGC and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Notice stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Notice, please do not access or use this website.

JURISDICTION-SPECIFIC INFORMATION

This Privacy Notice complies with the privacy provisions of Regulation S-P under the Gramm-Leach-Bliley Act and certain privacy provisions of other laws. You may have additional rights under other foreign or domestic laws that may apply to you, including as set forth in our additional jurisdiction-specific privacy notices.

Visitors that are residents of California should refer to our California Website Privacy Notice below.

If you are located in the United Kingdom (the “UK”), the European Union (the “EU”), or the European Economic Area (the “EEA”), or the processing of your personal data would otherwise be subject to the EU-UK Data Protection Laws (defined below), please also refer to our EU and UK Privacy Notice below.

THE INFORMATION WE COLLECT

We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, HGGC’s server collects general data pertaining to users, including the length of time spent on this website and the pages accessed while visiting the website. HGGC generally does not, however, collect any personally identifiable information such as names, home addresses, or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact HGGC” page or on the investor portal through our “LP Login” page.

To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for HGGC’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to HGGC, you consent to HGGC’s use of such personally identifiable information for the purposes described in this Privacy Notice.

CAPACITY

You represent to HGGC that you have the authority to visit this website according to the Termsof Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

COOKIES

Information regarding how you access this website (e.g., browser type and access times) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

Subject to your consent, the Website will place the cookies listed below:

Cookie Name: _ga
Cookie Type: Analytics
Cookie Purpose / Description: Used by Google Analytics to distinguish users and persist state.
Cookie Duration: 2 years

Cookie Name: _gid
Cookie Type: Analytics
Cookie Purpose / Description: Used by Google Analytics to store and count page views.
Cookie Duration: 1 day

Cookie Name: hggc_session
Cookie Type: Functional
Cookie Purpose / Description: Used by the website to track user-based authentication and functional information.
Cookie Duration: Session

Cookie Name: team_params
Cookie Type: Functional
Cookie Purpose / Description: Used by the website to track team section state.
Cookie Duration: Session

Cookie Name: portfolio_params
Cookie Type: Functional
Cookie Purpose / Description: Used by the website to track portfolio section state.
Cookie Duration: Session

Cookie Name: news_params
Cookie Type: Functional
Cookie Purpose / Description: Used by the website to track media section state.
Cookie Duration: Session

You can view an overview of Google’s privacy policies here: https://support.google.com/analytics/answer/6004245 You can also opt out of using Google Analytics cookies here: http://tools.google.com/dlpage/gaoptout

You may access any personally identifiable information we have about you by contacting compliance@hggc.com.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Notice (and any jurisdiction-specific privacy notices) from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Notice. Accordingly, users are strongly encouraged to review our Privacy Notice regularly. If we decide to change our Privacy Notice, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Notice under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Notice means that you accept such revisions, changes, and/or amendments. If you object to any of the changes to this Privacy Notice, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Notice carefully so you are aware of any changes, as they are binding on you.

MISCELLANEOUS

The provisions in our Terms of Use are hereby incorporated by reference.

CONTACT US

If you have any questions or concerns about this Privacy Notice, please contact compliance@hggc.com.

California Website Privacy Notice

LAST UPDATED: October 2024

This California Website Privacy Notice supplements the Website Privacy Notice with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

WHAT DOES THIS WEBSITE PRIVACY NOTICE APPLY TO?

This California Website Privacy Notice applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you deends on the nature of your interaction with us. The categories of personal information we may have collected from individuals on this Website over the last twelve (12) months include the following:

A. Identifiers (e.g., name, contact details, and address (including physical address and email address), and other identification (including social security number, passport number, and driver’s license or state identification card number));

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), verification documentation, and information regarding investors’ status under various laws and regulations (including social security number, tax status, income, and assets));

C. Protected classification characteristics under California or federal law (e.g., date of birth, citizenship, and birthplace);

D. Commercial information (e.g., account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience, and investment activity, information regarding a potential, and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, and source of funds used to make the investment in the applicable fund(s));

E. Internet or other similar network activity (e.g., use of our website, fund data room, and investor reporting portal (e.g., cookies, browsing history, and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries);

F. Geolocation data (e.g., physical location or movements);

G. Sensory data (e.g., audio, electronic, visual, thermal, olfactory, or similar information)

H. Professional or employment-related information (e.g., current or past job history or performance evaluations);

I. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) (e.g., education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records);

J. Inferences drawn from other personal information (e.g., profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes); and

K. Sensitive Personal Information (see further information on use of sensitive personal information below) (e.g., social security, driver’s license, state identification card, passport numbers; account log-in, financial account, debit card number, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sexuality, or sexual orientation).

We do not knowingly collect or solicit personal information from anyone under the age of 18.

We do not collect or use sensitive personal information other than:

To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmittedpersonal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
To perform services on behalf of our business;
To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we take reasonable steps to protect your personal data – and in this regard, we maintain physical, electronic, and procedural safeguards to prevent unauthorized access to your personal data and to protect the integrity of our systems - we cannot guarantee the security of any information or data transmitted to or through our Website; any transmission of information or data by you to or through this Website is at your sole risk.

HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?

In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:

Information from your communications with us in connection with this Website, including any update notices provided by you.
Information captured on our Website, including registration and account information, information provided through online forms, and any information captured via cookies.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We will use your personal information for one or more of the following business or commercial purposes:

Performing services to you, including but not limited to

The administrative processes (and related communication) in preparing for the admission of investors to the fund(s), including administering, managing, and setting up an investor’s account(s) to allow such potential investor to purchase interests in the fund(s);
Ongoing communication with potential investors, their representatives, advisors, and agents (including the negotiation, preparation, and signature of documentation) during the process of admitting potential investors to the fund and the execution of all relevant agreements;
The performance of obligations under the governing documents of the funds (and all applicable anti-money laundering, KYC, and other related laws and regulations) in assessing suitability of potential investors in the applicable fund;
Ongoing operations, administrative, accounting, reporting, account maintenance, and other processes and communication required to operate the business of the funds in accordance with its governing documents and other documentation between the parties, including customer service, processing or fulfilling transactions, verifying personal information, processing contributions and distributions, and financing;
Keeping investors informed about the business of the general partner or managing member of the applicable fund and its affiliates generally, including offering opportunities to make investments other than to the applicable fund and related advertising;
Facilitating the execution, continuation, or termination of the contractual relationship between an investor and the general partner or managing member, the investment adviser, and/or the fund(s);
Facilitating the transfer of fund interests, and administering and facilitating any other transaction, between an investor, the general partner or managing member, the investment adviser, and/or the fund(s);
Auditing and verifications related to investor interactions, including but not limited to, verifying the quality and effectiveness of services and compliance;
Maintaining the safety, security, and integrity of our products and services, databases, technology assets, and business, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity;
Enabling any actual or proposed assignee or transferee of the fund(s), to evaluate proposed transactions;
Facilitating business asset transactions involving the funds; and
Complying with U.S., state, local, and non-U.S. laws, rules, and regulations.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested.

We retain the categories of personal information set forth above in “What information do we collect about you?” section of this California Website Privacy Notice only as long as is reasonably necessary for those purposes set forth above in “How do we use your personal information?”, except as may be required under applicable law, court order, or government regulations.

WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to administrators, lenders, banks, auditors, law firms, governmental agencies, or pursuant to legal process, self-regulatory organizations, consultants, and/or placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical, and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

YOUR RIGHTS UNDER THE CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local, and non-U.S. laws, rules, and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure, and sale of personal information specific to You. Such information includes:

the categories of personal information we collected about you;
the categories of sources from which the personal information is collected;
our business or commercial purpose for collecting such personal information;
the categories of third parties with whom we disclose the personal information;
the specific pieces of personal information we have collected about you; and
whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local, and non-U.S. laws, rules, and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services, or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

CONTACT US

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: 888-462-2759

Email us at the following email address: compliance@hggc.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. We may also verify your request through a service provider. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

Please contact compliance@hggc.com with any questions about this California Website Privacy Notice.

EU and UK Website Privacy Notice

LAST UPDATED: October 2024

This EU and UK Website Privacy Notice supplements the information contained in the Website Privacy Notice above and applies solely to the processing of personal data which is subject to EU-UK Data Protection Laws. For the purposes of this EU and UK Privacy Notice and the Website Privacy Notice, the “EU-UK Data Protection Laws” means all applicable laws and regulations relating to privacy, the protection, and/or the processing of personal data in the EEA, EU, and UK, including (without limitation): the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the EU GDPR as it forms part of the laws of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (“UK GDPR”), as amended or supplemented. The terms “controller”, “data subject”,“personal data”, “process”, and “processing” have the meanings given to them in the applicable EU-UK Data Protection Laws.

WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA?

To the extent that EU-UK Data Protection Laws apply to our processing of your personal data,one or more of us are a “controller” of your personal data. In simple terms, when applicable, this means we: (i) “control” the personal data that we collect from you or other sources; and (ii) make certain decisions on how to use and protect such personal data.

WHAT TYPE OF PERSONAL DATA DO WE COLLECT?

The types of personal data that we collect are set forth in the “The Information We Collect”section of the Privacy Notice. Please note that we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

PURPOSES AND LEGAL BASES FOR COLLECTING AND USING PERSONAL DATA

We rely on various legal bases under applicable data protection legislation in order to process your personal information (e.g., name, title, address, email, marital status, date of birth, financial data, username, password, etc.), including our legitimate interests, contractual necessity, and as required by law. We use the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Further information about the legal bases under which we process your personal information is included in the section headed “Why we use your personal information.” You do not need to take any action as a result of this EU and UK Website Privacy Notice, but you do have certain rights as described below in the section headed “Your rights.”

HOW WE OBTAIN YOUR PERSONAL INFORMATION

Information you provide to us

We collect your personal information when you decide to interact with us, and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal information via online form, email, post, telephone, and this website.

Information provided by third parties or publicly available sources

We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).

WHY WE USE YOUR PERSONAL INFORMATION

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data: (i) where we need to perform the contract we are about to enter into or have entered into with you; (ii) where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests; and (iii) where we need to comply with a legal obligation. To the extent that you provide us with any personal information, through or in connection with this website (i.e., via telephone, email, or post) or the investor online portal, we may use such information for the following purposes:

a) To provide you with the services or products you have requested; b) To keep a record of your relationship with us; c) To verify your identity; d) To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to; e) Fraud and abuse prevention; f) Litigation management and conducting internal audits and investigations; g) To administer and protect our business and this website; or h) To make suggestions and recommendations to you about goods or services that may be of interest to you.

HGGC processes the personal information listed above in the legitimate interests of HGGC, except for in respect of paragraphs (a) and (c), which are respectively processed by contractual necessity and legal requirement. No automated decision-making, including profiling, is used when processing your personal information.

SHARING AND TRANSFERS OF PERSONAL DATA

In addition to disclosing personal data amongst ourselves, our affiliates, and our advisors and agents, we may disclose personal data, where permitted by EU-UK Data Protection Laws, to other service providers, employees, agents, contractors, consultants, professional advisers, lenders, data processors, and persons employed and/or retained by them in order to fulfill the purposes described in this EU and UK Website Privacy Notice. In addition, we may share personal data with regulatory bodies having competent jurisdiction over them, as well as with tax authorities, auditors, and tax advisors (where necessary or required by law, rule, or regulation).

We may transfer personal data to a Non-Equivalent Country (as defined below), in order to fulfill the purposes described in this EU and UK Website Privacy Notice and in accordance with applicable law, rule, or regulation, including where such transfer is a matter of contractual necessity. For information on the safeguards applied to such transfers, please contact compliance@hggc.com. For the purposes of this EU and UK Website Privacy Notice, “Non- Equivalent Country” shall mean a country or territory other than (i) a member state of the EEA; or (ii) a country or territory which has at the relevant time been decided by the European Commission in accordance with EU-UK Data Protection Laws to ensure an adequate level of protection for personal data.

RETENTION AND SECURITY OF PERSONAL DATA

HGGC and its affiliates consider the protection of personal data to be a sound business practice, and to that end, we employ appropriate technical and organizational measures, including robust physical, electronic, and procedural safeguards to protect personal data in our possession or under our control.

Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including operating partners and other consultants, recruitment firms, placement agents, and data hosting providers. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Personal data may be kept for as long as it is required for legitimate business purposes, to perform contractual obligations, or where longer, such longer period as is required by applicable legal or regulatory obligations.

CAPACITY

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

COOKIES

YOUR RIGHTS

You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. Under EU-UK Data Protection Laws (where applicable), you have the right: (i) to obtain information about, or withdraw any consent given in relation to, the processing of your personal data; (ii) to access and receive a copy of your personal data; (iii) to request rectification of your personal data; (iv) to request erasure of your personal data; (v) to exercise your right to data portability; and (vi) the right not to be subject to automated decision-making. Please note that the right to erasure is not absolute and it may not always be possible to erase personal data on request, including where the personal data must be retained to comply with a legal obligation. In addition, erasure of the personal data requested to fulfill the purposes described in this EU and UK Website Privacy Notice, may result in the inability to provide necessary services. To exercise these rights and controls, please contact compliance@hggc.com.

NOTIFICATION OF CHANGES

We reserve the right to amend this EU and UK Website Privacy Notice from time to time by updating this EU and UK Website Privacy Notice. If we decide to change our EU and UK Website Privacy Notice, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with this EU and UK Website Privacy Notice under which the information was collected.

CONTACT US

If you have any questions or concerns about this EU and UK Website Privacy Notice, please contact compliance@hggc.com.

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office ‘ https://ico.org.uk/global/contact-us.’

TRANSPARENCY OF SUSTAINABILITY RISK POLICIES (ARTICLE 3, SFDR)

HGGC integrates sustainability risks into investment analysis and decision-making in line with the application of HGGC’s Responsible Investment Policy, consistent with and subject to any applicable legal, regulatory, fiduciary, or contractual duties. Please see HGGC’s Responsible Investment Policy for further details.

NO CONSIDERATION OF ADVERSE IMPACTS OF INVESTMENT DECISIONS ON SUSTAINABILITY FACTORS (ARTICLE 4, SFDR)

HGGC does not consider adverse impacts of investment decisions on “sustainability factors” as specifically defined by the SFDR. It has elected not to do so at the present time as it considers its existing policies and procedures to be appropriate, proportionate, and tailored to the investment strategies of its funds. HGGC will continue to monitor changes to applicable requirements of the SFDR and may, in the future, consider such adverse impacts, as appropriate in the context of its funds and subject to any applicable legal, regulatory, fiduciary, or contractual duties.