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Privacy Policy

Effective Date: January 2024

We are committed to respecting your privacy. Please read this Privacy Policy carefully. This Privacy Policy describes how Brighton Park Capital Management, L.P. and its related entities (“Brighton Park”, “we”, “us” or “our”) may collect, use, share, and disclose personal information we collect on the websites owned and operated by Brighton Park (the “Sites”). This Privacy Policy applies to information collected (a) from you via the Sites; (b) from you when you interact with Brighton Park on phone or video calls, at events, as part of Brighton Park-sponsored programs, or in other contexts; and (b) from “third party” sources in the course of managing Brighton Park’s portfolio of investments and consideration of new investments. Unless otherwise stated, this Privacy Policy does not apply to your use of Brighton Park’s financial services, including any investments.

If you have any questions about this policy or whether it applies to you, please contact us at hello@bpc.com.

BY PROVIDING YOUR PERSONAL INFORMATION TO BRIGHTON PARK OR OTHERWISE USING OUR SITES, YOU AGREE TO THE TERMS OF THIS POLICY AND OUR WEBSITE TERMS OF USE.

The Information We Collect and Use

When we use the term “Personal Information” we mean information that can be used to identify you as an individual person. We may collect and use two categories of Personal Information through your use of our Sites.

1. Personal Information You Provide To Us:

- We collect personal information when you choose to share that information with us.

- When you submit identifiable comments or other content to us, we collect whatever information you supply and use this information to communicate with you if requested, and otherwise fulfill the purpose of the content submission.

- When you sign up for our newsletter or account updates, we collect your contact information and communication preferences, which we use to manage how we communicate with you.

Information Collected Automatically:

- We use various technologies to collect other types of data that do not directly reveal your identity (“Other Information”). If we associate Other Information with Personal Information, we will treat the combined information as Personal Information in accordance with this Privacy Policy.

- Logging Functionality: We may gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data. We generally only use this data for purposes such as security, fraud detection, and protecting our rights.

- Cookies and Other Data Collection Technologies: We and our service providers may use cookies, scripts, and similar technologies to manage our websites and to collect information about you and your use of our Sites. These technologies help us to recognize you, customize or personalize your experience, and analyze the use of our Sites to make them more useful to you. Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your Internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Sites.

- Analytics: We use third-party analytics providers such as Google Analytics to help us evaluate the Sites. To opt out of the aggregation and analysis of data collected about you on our website by Google Analytics, visit https://tools.google.com/dlpage/gaoptout and download and install the Google Analytics Opt-out Browser Add-on.

Cookies

Cookies are small text files that are placed on your device (computer, smartphone, tablet) when you visit a website. They are widely used to make websites work more efficiently and provide essential functionality. Cookies can also provide information to website owners for various purposes, including analytics and marketing.

Types of Cookies We Use

We use the following types of cookies on our Sites:

  1. Essential Cookies: These cookies are necessary for the basic functioning of our Sites. They enable you to navigate our Sites and use their features. Without these cookies, the Sites may not work correctly.
  2. ‍Performance Cookies: These cookies collect information about how visitors use our Sites, such as which pages they visit most often and any error messages they may encounter. This information is used to improve the Sites’ performance and user experience.
  3. Functional Cookies: These cookies allow the Sites to remember choices you make (such as your username or language preference) and provide enhanced, personalized features.
  4. Targeting or Advertising Cookies: These cookies are used to deliver content and ads relevant to your interests. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns.

Third-Party Cookies

As noted above, we may also allow third-party service providers to use cookies on our Sites to collect information about your online activities across different websites. These providers may include but are not limited to analytics services, social media platforms, and advertising networks. We do not control these third-party cookies and their use is governed by the privacy policies of the respective third parties.

How to Manage Cookies

You can manage or delete cookies at any time by adjusting your browser settings. Most web browsers allow you to control and block cookies through their settings. Please note that blocking or deleting cookies may affect the functionality of our Sites and may limit your ability to use certain features.

Additional Purposes For Which We Collect And Use Information

Some jurisdictions require that organizations have a “lawful basis” for processing or sharing any personal information. Brighton Park uses and shares your information for a variety of lawful purposes. In addition to the uses described above, we may use your Personal Information for the following purposes:

  • Operating our business;
  • Contacting you to respond to your requests or inquiries and provide user support;
  • Contacting you about programs, products, or services that we believe may be of interest to you, new product or service announcements or event invitations;
  • Creating, improving and developing our products and services;
  • Preventing, investigating, or providing notice of fraud, unlawful or criminal activity, or unauthorized access to or use of Personal Information, our website or data systems; or to meet legal obligations;
  • Investigating and resolving disputes and security issues and enforcing our Terms & Conditions of Use and other agreements; and
  • Any other lawful, legitimate business purpose.

When We May Share Information With Others

We share your Personal Information with third parties in the ways described in this Privacy Policy.

‍Service Providers: We share your Personal Information with third party service providers who perform services on our behalf or for your benefit, such as web hosting or verifying user data.

‍Affiliates: We may share your information with affiliated legal entities within our family of companies for purposes and uses that are consistent with this Privacy Policy.

‍Legal Process, Safety and Terms Enforcement: We may disclose your Personal Information to legal or government regulatory authorities in response to their requests for such information or to assist in investigations. We may also disclose your Personal Information to third parties in connection with claims, disputes or litigation, when otherwise required by law, or if we determine its disclosure is necessary to protect the health and safety of you or us, or to enforce our legal rights or contractual commitments that you have made.

‍Business Transfers: Your Personal Information may be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could be transferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the event of insolvency, bankruptcy, or receivership. We will use reasonable efforts to direct the transferee to use your Personal Information in a manner that is consistent with our Privacy Policy.


Accessing and Updating Your Information

You may request a copy of the information which we hold about you (for which we may charge you a small fee for large or complex requests). In addition, if you would like to access, verify, correct, update or delete your e-mail address, mailing address or other personal information with us please contact us directly.

User Rights under Applicable Data Protection Laws

Depending on the country or jurisdiction in which you are located, you may have certain data subject rights pursuant to data protection laws applicable to users in your jurisdiction.  Brighton Park appreciates the importance of protecting privacy in accordance with such laws. We ask that you please read this Privacy Notice carefully to understand how we collect, share, and protect the personal information of investors and users in each jurisdiction. If there are any conflicts between the terms in this Privacy Policy and the applicable data protection laws, the terms of such laws will govern.

These rights vary by jurisdiction, but they may include:

  • The right to be informed about the processing of your Personal Information.
  • The right to have access to your Personal Information.
  • The right to update and/or correct your Personal Information.
  • The right to portability of your Personal Information.
  • The right to oppose or limit the processing of your Personal Information.
  • The right to request that we stop processing and delete your Personal Information.
  • The right to block any Personal Information processing in violation of any applicable law.
  • The right to launch a complaint with a data protection regulator in your jurisdiction.

If you are accessing this website from the European Union or United Kingdom (UK), under the General Data Protection Regulation (“EU GDPR”) and the UK Data Protection Act 2018 and other legislation (“UK GDPR”) you have a number of the above rights with regard to your “personal data” (as such term is defined in the EU GDPR or the UK GDPR, as applicable).

Similarly, if you are a resident of the Cayman Islands, the Cayman Islands’ Data Protection Law, 2017 provides you with certain rights with respect to your personal information.

To learn more about these rights, to lodge a complaint, or to exercise any of these rights, please contact us as indicated below. We will process such requests in accordance with Applicable Data Protection Laws.

California Residents

‍If you are a resident of California, please review the California Privacy Notice below, which explains the types of personal information we collect that are subject to the California Consumer Privacy Act, as amended (“CCPA”), as well as your rights under the CCPA.

Use and Transfer Outside of the United States

Brighton Park primarily stores the information described above in the United States. You should only use the Sites and submit information to Brighton Park if you are comfortable that your data will be stored in the United States. By using the Sites and/or providing information to Brighton Park (whether you are located in the United States or elsewhere), you acknowledge and agree that your personal information may be processed in the methods and for the purposes identified in this Privacy Policy.

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of certain of your personal information to various countries around the world (including the United States) that may have privacy laws that are less protective than those in the country or jurisdiction in which you are located. By providing your data, you consent to such transfers.

Other Websites

You may find links on our Sites that navigate to third-party websites that we do not own or control (each, a “Third-Party Site”). These websites should have their own privacy policies, which you should check.

In particular, please note that if you access your investor account through the Sites, you may leave our Sites and navigate to a Third-Party Site. In order to set up your investor account, we may have provided the third party website with certain account details (for example, name, job title and company name, email and physical address, phone number, username, password, demographic or investment information) that you submitted to us separately from your use of the Sites. This Privacy Policy does not apply to, and we are not responsible for, the practices of the third party that administers your investor account.

We strongly advise that you refer to the privacy policy on each Third-Party Site to understand what information they may collect and how it is used. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Additionally, certain websites or platforms owned or controlled by us may be subject to additional or alternative privacy policies and conditions specifically applicable to such websites or platforms. You should review such policies and conditions carefully.

How We Protect Your Data

We have put in place reasonable administrative, personnel, technical and physical security measures to prevent your Personal Information from being accidentally lost, used, altered, disclosed, or accessed without authorization.

Please note, we may use facilities outside of your home country to process, store, or back up electronic information.

Data Retention

We will retain your personal data for as long as reasonably necessary in connection with the purposes described in this Privacy Policy, for as long as we have a legitimate business need to do so (including as necessary to resolve disputes and enforce agreements), or as otherwise required to comply with our legal or regulatory obligations or data retention policies.

The retention period applicable to your personal data is determined by considering a number of factors, including the nature of your data, the purposes for which it is being used and applicable legal requirements.

Children’s Privacy

We do not intentionally collect or solicit Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a user under the age of 13, we will attempt to delete this information from our records. If you believe that we might have any information from or about a child under 13, please contact us.

Changes To This Policy

We may update our Privacy Policy from time to time to reflect changes to our practices or for any other reason. If we make any changes, we will notify you by revising the "Effective Date" at the top of this policy and, in some cases, where appropriate we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). Such changes will be effective upon posting, unless otherwise stated or required by law.

We encourage you to review our Privacy Policy whenever you access our Sites to stay informed about our information practices and the ways you can help protect your privacy.

Contact Us

If you have any questions or comments about this Privacy Policy or other privacy-related matters, you may contact us in the following ways:


  • Email: hello@bpc.com
  • Mailing Address: Brighton Park Capital, 330 Railroad Ave, Suite 200, Greenwich, CT 06830
  • Phone Number: 203-542-0750

California Privacy Notice

This California Privacy Notice (“Notice”) is for California residents and supplements our Privacy Policy. It explains how we collect, use, and disclose your Personal Information and how to exercise your rights under the California Consumer Privacy Act of 2018, as amended (“CCPA”).

Note that when we say “Personal Information” in this Notice, we mean 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 aggregated or information that cannot be reasonably linked to you.

As a California resident, you have the rights summarized below, among others. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

How We Collect, Use, and Disclose Personal Information

When you use our Sites or otherwise interact with us, we may collect certain Personal Information about you.

We do not sell or share any of your Personal Information.

Under the CCPA, California Residents can request certain information about how we have collected and used your Personal Information during the past 12 months. The following is a summary of the categories of Personal Information we may have collected about you during the past 12 months. To learn more about the kinds of information we collect and how we use it, we recommend that you review our Privacy Policy or reach out to us directly.

Categories of Personal Information We May Have Collected About You

- Identifiers: This may include name, address, phone number, alias and e-mail address.- Online Identifiers: This may include cookies, web server logs, web beacons, and other website tracking information or user activity.

- Professional/Employment and Education Information: This include employment history, occupation, title, and employer information, education and such other information that you provide or is otherwise publicly available.

- Inferences: This may include information that can create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

- Protected Classification Characteristics: This may include race, ancestry, national origin, religion, age, mental and physical disability, sex, sexual orientation, gender identity, medical condition, genetic information, marital status, or military status. We do not intentionally collect this information but it may be revealed in identity data or other information we collect.

- Other Information: Audio, electronic, visual, thermal, olfactory, or similar information.

Purposes for Collecting Your Personal Information

We may have gathered your Personal Information for the reasons set out in our Privacy Policy.

Potential Recipients of Your Personal Information

Your Personal Information may have been shared with certain parties, as set out in our Privacy Policy.

Sources of Personal Information

Personal Information may come from a variety of sources, including you, your device(s), our portfolio companies or affiliates, third parties or services providers that provide service to you or perform services for us on our behalf, and publicly available sources.

Please note that some of the information we collect about you, such as racial or ethnicity information, may be considered “sensitive personal information” under CCPA.

Your Rights

Information, Access and Data Portability

You have the right to request certain information about how we have collected and used your Personal Information during the past 12 months. You may also request information about any disclosure of your private information to third parties. You may request that we limit the use of your Personal Information.

You also have the right to request a copy of the Personal Information that we have collected about you during the past 12 months.

Deletion and Correction

You have the right to request that we delete or correct the Personal Information that we have collected from you.

Nondiscrimination

Under the CCPA, You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

How You Can Exercise Your Rights Provided Under the CCPA

To exercise any of these rights, please contact us in the following ways:

  • Email: hello@bpc.com
  • Mailing Address: Brighton Park Capital, 330 Railroad Ave, Suite 200, Greenwich, CT 06830
  • Phone Number: 203-542-0750

Please note that to protect the integrity of our services and to protect your privacy interests, we may need certain additional information from you, for verification purposes, before processing your request.

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