Privacy Policy

EU WEBSITE PRIVACY POLICY

 

OUR COMMITMENT TO PRIVACY

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

This Privacy Policy describes how we gather and use information for visitors of this website. Please read this Privacy Policy carefully.

For the purposes of applicable EU laws, Ken O’Keefe, Brendan J. Spillane, Shirley Knight and Ariana Scotti will each be a data controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this Privacy Policy, please contact dataprivacyofficer@vestarcapital.com.

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, social security number, date of birth, passport number, nationality, place and date of birth, gender, IP address, tax status, education and employment information, banking, financial and transactional data (e.g. bank account details for wire transfers and other purposes relating to our investment activities), username, passwords), 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, or information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences, unless it is specifically related to a legal obligation of ours.

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. If you fail to provide the requested information, it may mean that we cannot provide our services or products to you. In this case, we may have to cease providing 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 Privacy Policy, 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 email, US or international mail services, via our or our third-party administrator’s website and via telephone.

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. This personal information is obtained via third parties (i.e., the company in question or its attorneys or other agents or authorized representative).  Any information collected in this way is only used either in connection with our determination of whether to proceed with a particular investment transaction or in connection with the ongoing evaluation, management and/or disposition of a company in which we have invested.

 

WHY WE USE YOUR PERSONAL INFORMATION

To the extent that you provide us with any personal information, we may use such information for the following purposes:

Purpose Legal Basis
  • To provide you with the services or financial products you have requested.
  • Contractual necessity
  • To keep a record of your relationship with us.
  • Legitimate interest
  • To verify your identity.
  • To fulfill our legal requirements
  • To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are a party.
  • Legitimate interest
  • To provide ongoing management and monitoring of a corporate transaction or investment with respect to which we are a party.
  • Legitimate interest
  • Anti-money laundering screening, know your customer and fraud and abuse prevention.
  • To fulfill our legal obligations
  • To administer and protect our business and our website
  • Legitimate interest

 

MARKETING

We send direct marketing communications based on our legitimate business interests where we have an existing relationship with you and we when wish to contact you about similar products or services in which you may be interested.  For purposes of this paragraph, the term “marketing communications” is (A) limited to offering memoranda, pitch books or other documents associated with fundraising in vehicles in which the investor does not maintain a current investment and (B) does not include regular communications with investors that currently hold an interest in a Vestar-managed investment vehicle, such as quarterly and annual reports, updates on specific investments, or other communications regarding an existing investor’s investments with Vestar.

 

DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, 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.

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 professional advisors (including attorneys, accountants, and third party administrators), service providers for tax preparation and reporting, banks, our information technology consultants and data hosting providers. We make sure anyone who provides a service to, or for us, agrees to comply with our standards for data security. To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards/derogations used, please contact dataprivacyofficer@vestarcapital.com.

We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

 

SECURITY AND RETENTION OF PERSONAL INFORMATION

We are committed to protecting the personal information you entrust to us. We implement appropriate technologies and adopt appropriate policies, so the information we have about you is protected to the extent practicable from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to an obligation to keep your personal data confidential pursuant to agreements that we have in place with them.

We have procedures to deal with a suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact dataprivacyofficer@vestarcapital.com.

 

CAPACITY

This website is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.