Privacy Policy

Privacy Policy

(as of June 2024)

This Privacy Policy (the “Policy”) describes how Quad-C Management, Inc. and its affiliates (the “Firm”, “we”, “us” or “our”) may collect, use, share and otherwise process personal information through our website at <https://www.quadcmanagement.com> (the “Site”), as well as information that we may collect about you via other means, as described below (“you” or “your”). While our Site does not currently collect personal information as of the last updated date of this Policy except through its investor portal, we reserve the right to collect personal information on this Site in line with the terms of this Policy.

If you are an investor in a fund or the holder of an account managed directly or indirectly by us (or, in either case, their representative), please refer to the Privacy Notice (or similar) (as available in our investor portal or otherwise provided to you) for further information about how we collect and process personal information about current, prospective and former investors.

I. Personal information we collect

"Personal information” is any kind of information that allows us to identify a natural person or the household of a natural person, directly or indirectly, such as your name, contact details, or address. We may collect and process, and in the twelve (12) months preceding the effective date of this Policy have collected and processed, the following personal information:

• Identifiers, such as name, address, email address, telephone numbers, and social security number;

• Commercial information, including tax information, bank account details, records of transactions and source of funds;

• Professional or employment information, such as job title and place of work;

• Internet or other electronic network activity information, such as internet protocol (IP) address, login data, unique device identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, mobile device carrier and other technology on the devices used to access the Site; as well as usage information, such as information about use or the Site and our services, referring/exit web pages, date/time stamps, error logs, and the frequency of use of the Site; and

• Marketing and communications information, such as your preferences in receiving marketing communications from us.

We may also collect, use, and share aggregated information such as statistical or demographic data for any purpose. This information could be derived from personal information but will not directly or indirectly reveal your identity. For example, we may aggregate Site usage information to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect information with personal information so that it can directly or indirectly identify a natural person, we treat the combined information as personal information which will be used in accordance with this Policy.

II. How we collect your personal information

We collect personal information from you via the following:

     A. Personal information you provide to us or collected as part of transactions

1. Subscription or other forms you complete (or which are completed by your authorized representatives on your behalf) on the Site or otherwise;

2. Your correspondence and interactions with us, including by letter, email and telephone; and

3. From investors or potential investors, as a result of transactions with us or our affiliates, or with our investors or others.

     B. Personal information collected from third parties and service providers

We may collect personal information about you from third parties and service providers, such as business partners, vendors, or from publicly available information. The conditions under which we may obtain such information are governed by the third-party source.

C. Information collected automatically

We may automatically collect certain information about the devices you use to access the Site, as well as information on interactions with the Site, through cookies, web server logs, and other similar tracking technologies.  This information may include the IP address used computer and connection information such as your browser type and version; operating system and platform; confirmation when you open email that we send you; and the URLs which lead you to and around the Site including the date and time of access.

1. Cookies and other data collection technologies

“Cookies” are a feature of web browser software that allows web servers to recognize the computer used to access a website. They are small text files that are stored by a user’s web browser on the user’s hard drive. Cookies can remember what information a user accesses on one website to simplify subsequent interactions with that site by the same user or to use the information to streamline the user’s transactions on related websites. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies last longer and are used to recognize your computer when you return to the Site. Cookies are designed to make your online experience easier and more personalized.

Web server logs are files that store the activity on a certain website.

Information gathered through cookies and web server logs may include information such as the date and time of visits to the Site, the pages viewed, time spent at the Site, and the websites visited just before and just after the Site. Most web browsers automatically accept cookies. You can change your browser settings to notify you of the cookies being set or updated, and to block or delete cookies. Please note that if you have turned off all cookies, some features of the Site may not be available to you or otherwise function as intended. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.

Information gathered through tracking and analytics solutions may include the information gathered in web storage logs, activities while browsing the Site (for example, scrolling down a page), and information regarding the device used to access the site. In the case of third-party tracking and analytics solutions, information collected may also include identification numbers assigned by the analytics solution provider to associate browsing activity to a given user across websites.

2. “Do Not Track” Browser Settings

We do not currently use technology that recognizes “do not track” signals from your web browser.

III. How we use your personal information

We will only use your personal information when and how the law allows us to. Any of the personal information we collect about you may be used for one of the following business purposes:

• Where the processing is necessary for us to enter into or to perform a contract with you, or to take steps at your request prior to entering into a contract – for example, to provide information you have requested or to respond to your questions;

• Where necessary for the purposes of the Firm’s legitimate interests, including to operate and facilitate our business and services, communicate with you, undertake business management, planning, statistical analysis, market research and marketing activities, administer and maintain the Firm’s records, protect the Firm’s rights and interests, ensure the security of the Firm’s assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, and enforce our terms and conditions or in connection with the sale or reorganization of some or all of our assets or the Firm itself;

• Where required by applicable laws and regulations, including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions; and

• Where the processing is necessary for the establishment, exercise or defense of legal claims.

In some circumstances, we may also process your personal information where we have received your consent. For example, depending on where you are located, in order to send you marketing materials or to place cookies or similar tracking technologies on your devices. Where processing is based on your consent, you have the right to withdraw that consent at any time.

In addition to the bases discussed above, we may process portfolio company personal information in order to provide management and advisory services to our portfolio companies or otherwise for our legitimate interests, which also include: conducting research and due diligence into potential investment targets; preparing reports on investment targets; reviewing, monitoring and managing our investment portfolio; business management and planning; corporate transactions; administration and maintenance of our records.

IV. How we protect your personal information

We are committed to maintaining the confidentiality, integrity and security of your personal information and take reasonable precautions to protect such information. These precautions include the adoption of certain physical, electronic, and procedural safeguards and procedures designed to maintain and secure your personal information from inappropriate disclosure in accordance with applicable laws and regulations. We do not intend to guarantee or otherwise represent that these precautions will be sufficient to preclude unauthorized access to personal information or compromise of its security, integrity, or availability.

Our policies require that access to personal information be restricted to those employees and agents of the Firm who need to know that information in order to provide the Firm’s services. We may disclose such information to our service providers (including financial, technical, marketing and professional service providers and consultants) and financial institutions that provide services to the Firm. We require such third-party service providers and financial institutions to protect the confidentiality of your personal information and to use the information only for purposes for which it is disclosed to them.

V. When we disclose your personal information

We do not sell personal information obtained about you to any third parties and have not done so in the twelve (12) months preceding the effective date of this Policy.

We may use certain third-party solutions on our website to provide us with analytics and similar services. The use of such services may be considered a “sale” under the California Consumer Privacy Act, although that law is generally not applicable to our relationship with our investors.

We do not disclose any personal information to anyone other than our affiliates, service providers and relevant counterparties without your consent, or as required by applicable law or regulation. This means that we may disclose your personal information to other third parties, including:

• Any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over the Firm or its affiliates, if (i) the Firm determines that such disclosure is necessary or advisable pursuant to, or in connection with, any U.S. federal, state or local, or non-U.S., law, rule, regulation, executive order or policy, including, without limitation, any anti-money laundering law and the USA PATRIOT Act and (ii) such disclosure is not otherwise prohibited by law, rule, regulation, executive order or policy;

• Persons acting in a fiduciary or representative capacity on behalf of an investor, such as an IRA custodian or trustee of a grantor trust; and

• Certain other persons to the extent authorized by you.

No mobile information will be sold or shared with third parties/affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

When it is necessary for us to share your personal information with other parties, we will require that such information only be used for the limited purpose for which it is shared and will advise such third parties not to further share your information with others except to fulfill that limited purpose.

We do not disclose personal information except as may be required or permitted by law, rule or regulation. We may disclose for a business purpose and have disclosed in the preceding twelve (12) months, personal information, including contact information, employment information, identification information, background information and financial information to third parties, as listed above.

We may aggregate survey responses for publication. However, this will not include any non-public personal information or any information identifiable to a particular Site user.

If the Firm sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger, restructuring or business transfer, the Firm may transfer your personal information to a third-party purchaser or associated professionals as part of that due diligence and transaction process.

VI. How we transfer your personal information

Because the Internet and our operations are global, the personal information that we collect about you or that you submit to us may be transferred to, processed in, and held in countries (including the United States) other than the one in which you reside. Such transfers and processing are a necessary part of the services that we provide.

While the European Union and United Kingdom do not consider the United States and many other countries to provide essentially equivalent privacy protections, to the extent required by and in accordance with applicable data protection laws, we rely on appropriate or suitable safeguards to ensure such transfers are lawful, including:

• Where the relevant country or recipient has been deemed to provide an adequate level of protection for your personal information by relevant authorities;

• Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards;

• Obtaining your consent to transfer personal information after first informing you about the possible risks of such a transfer;

• Transferring the personal information because it is necessary for the performance of (or to enter into) a contract between you and the Firm, or because the transfer is necessary for the performance of a contract between the Firm and a third party, and the contract was entered into in your interest; and

• Transferring the personal information because it is necessary to establish, exercise or defend legal claims.

For more information on the safeguards we have in place, please contact us using the details below.

VII. Retention of your personal information

We will retain your personal information only for as long as is necessary for the purposes set out in this Policy, or as long as we are legally required or permitted to do so. Under certain circumstances, you may have the right to have your personal information erased.

When deciding how long to retain your personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information described above and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

VIII. Third-party links

The Site may contain links to third-party websites, products and services. These third-party websites and services have separate and independent privacy policies, which we encourage you to read. We have no responsibility or liability for the content and activities of such linked sites. However, we want to protect the integrity of our Site and thus welcome any feedback you may have about third-party sites we link to.

IX. Children’s Privacy

The Site is not directed toward children under the age of 18. We do not promote our products or services online to minors, and we do not intentionally collect any personally identifiable information from any person under 18. If we become aware of having collected personal information from children under the age of 18 without valid consent from their respective parents or guardians, we will delete it as soon as practicable.

X. Changes to your personal information

You are not required to supply any of the personal information that we may request, except where such information is necessary for the performance of (or to enter into) a contract with you or is otherwise required by applicable law. However, failure to do so may result in our being unable to accept your business or provide services to you. We will make reasonable efforts to ensure that all information that we hold about you is accurate, complete and up to date. You can help in this regard by promptly notifying us at the address listed below if there are any changes to your personal information.

XI. Changes to this Policy

We may update this Policy periodically, without prior notice, so please review it frequently. If we decide to change this Policy, we will post those changes on the Site so that you are aware of what kinds of personal information we collect, use, share and otherwise process. If we make material changes to this Policy, we will notify you on this Site, update the effective date above, and provide you with notice as required by applicable law. Material changes will not be applied retroactively without your consent.

XII. Data Subject Rights

We are committed to providing individuals with reasonable and appropriate access to their personal information. If you believe that we are processing personal information about you and wish to have access to that information, we will make reasonable efforts to provide you with that data or at least an explanation of why we cannot do so in the particular context, such as where the request is manifestly unfounded or excessive. We are happy to correct inaccurate data or delete information that is not appropriate to retain.

Individuals in Andorra, Argentina, Australia, California, Canada, Cayman Islands, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal information; (ii) restrict or object to the processing of their personal information; (iii) obtain a copy of their personal information in a portable format; and (iv) object to certain personal information processing activities.

For example, when California privacy law applies, residents have the right to know whether their information has been sold or shared, to know what personal information about them has been collected, to request the deletion of their personal information, to correct their personal information, and to opt-out of the sharing of their personal information for behavioral advertising purposes. The California Consumer Privacy Act (“CCPA”) prohibits covered businesses from discriminating against you for exercising applicable CCPA rights.

Individuals may also have the right to lodge a complaint about the processing of personal information with a data protection authority. We are always open to dialogue to resolve issues short of formal disputes. If your concerns cannot be resolved, we can enter into appropriate third-party neutral dispute resolution. If you need to reach us about a privacy or data protection issue, please contact us using the details below.

If you wish to exercise any of these rights, please email Investor.Service@qc-inc.com or call us at (434) 979-2070. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your personal information only in de-identified form, we will not attempt to re-identify your data in response to a data subject rights request.

If you make a request related to personal information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request.

For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

Should you need to access this Policy in a different format due to disability, please contact us using the information below.

XIII. Contact Us

If you have any questions or concerns about this Policy, please contact us at: