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Privacy Notice

Last Updated April 2020

This privacy notice applies to the Internet sites of Thoma Bravo, L.P. and Thoma Cressey Bravo, Inc. (together, "Thoma Bravo" or "we", or “our” or “company”), including www.thomabravo.com and www.tcb.com (together or separately, the “Site”). We are committed to respecting the privacy of the users of our Site. We have established and implemented this privacy notice to inform you, the user of the Site, of the type of information we collect and how we use and protect such information. Please read this privacy notice carefully.

Except where EU laws apply to the processing of your personal information, by providing your personally information to us, you signify your acceptance of this privacy notice and agree that we may collect, use and disclose your personal information as described in this privacy notice. If you do not agree to this privacy notice, please do not provide your personal details to us.

This privacy notice is incorporated into, and part of, the Terms of Use, which govern your use of the Site in general.

Thoma Bravo reserves the right to amend this privacy notice in its sole discretion from time to time. Thoma Bravo will post any changes to this privacy notice on the Site so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it, and such changes shall be effective immediately upon posting. 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. Except where California, EU or other laws apply to the processing of your personal information, your provision of personal information after any such changes constitutes your acceptance of the new terms and conditions.

For the purposes of applicable EU laws, Thoma Bravo will 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 notice, please contact Thoma Bravo at 1-800-221-0583 or compliance@thomabravo.com. You can also submit inquiries using the Contact page of the Site (https://www.thomabravo.com/contact).

This privacy notice generally does not address our privacy practices concerning any nonpublic personal information we collect from our investors, potential investors or employees (including prospective employees or contractors) through sources other than the Site; our practices related to nonpublic personal information we collect from our investors, potential investors or employees (including prospective employees or contractors) are addressed in separate notices.​

Table of Contents

  • Information We Collect
  • How We Use Information Collected
  • Marketing
  • With Whom Do We Share the Information We Collect
  • Transfers of Personal Information Outside the EEA
  • Security
  • Minors
  • Cookies
  • Your EU Rights
  • Your California Rights
  • Questions and Comments

Information We Collect

Information you provide to us

In general, you can visit the Site without telling us who you are or revealing any information about yourself.

We collect your personal information when you decide to interact with us, including when you submit information using the contact options provided on the Site. You can also provide us with personal information via email, post and telephone. This personal information may include your name, email address, address, title, job title, position, telephone number and IP address. We may collect additional personal information about you depending on how you interact with us. See below for further information on ‘How We Use Information Collected’.

Information we collect automatically

Thoma Bravo collects certain information about your use of, and interaction with, the Site, including information about how users are directed to our Site and visitor paths through the Site (which helps us improve Site design and usefulness), unique visitors and Internet Protocol (“IP”) addresses (used to improve our level of service and the content of our Site). We also collect certain information through cookies, described below. Thoma Bravo does not collect any personal data that can be used to directly identify a Site visitor, such as names, home addresses or email addresses.

IP addresses and cookie identifiers may be considered “personal data” in certain jurisdictions and will be treated in accordance with this Privacy Policy.

Thoma Bravo will process personal data collected through the Site as necessary for our legitimate business interests or other legal basis as noted below.

Information provided by third parties or publicly available sources

We may collect personal information about you from third parties including from our affiliates, our portfolio companies, job posting websites, recruiting firms and social media sites.

Information provided under a legal obligation

If we collect 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

How We Use Information Collected

If you provide us with any personal information, through or in connection with this Site (i.e., via telephone, email, or post), we may use such information for the following purposes:

Purpose

Legal Basis

To provide you with the services or financial products you have requested (e.g., responding to an inquiry).

Contractual necessity

For our administration, research, and other business operation purposes.

Legitimate interest

To keep a record of your relationship with us.

Legitimate interest

To verify your identity.

Legal requirement and legitimate interest

To process inquiries about employment opportunities.

Legitimate interest or pre-contractual necessity

To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.

Legitimate interest

Fraud and abuse prevention.

Legal requirement and legitimate interest

Litigation management and conducting audits and investigations.

Legal requirement and legitimate interest

To administer and protect our business.

Legitimate interest

To make suggestions and recommendations to you about goods or services that may be of interest to you.

Legitimate interest

 

Note that we may process your personal data on more than one basis depending on the specific purpose for which we are using your personal information.

Marketing

We may send you direct marketing communications to keep you informed of our services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-out to certain kinds of marketing at any time by emailing ir@thomabravo.com.

With Whom Do We Share The Information We Collect

Your personal information will be shared with and processed by:

  • our affiliates;
  • certain service providers as necessary to fulfill the purposes set out in this privacy notice, including professional advisors, recruitment firms, consultants, and data hosting providers.

We endeavor to ensure that anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.

We reserve the right to disclose your personal information to third parties, including, but not limited to, law enforcement or other governmental agencies, in order to comply with law or when we believe that disclosure is necessary to enforce or protect our rights in or otherwise with respect to, or the safety of, our Site or to protect the safety or rights of other users of our Site 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 takeover, divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors.

Transfers of Personal Information Outside The EEA

Your personal information will be hosted in the U.S. and will therefore be transferred and stored outside of the European Economic Area (“EEA”). For the purpose of applicable EU laws, such third countries (including the U.S.) may not offer the same level of data protection as your country of residence. Such transfers will be made in accordance with applicable EU data privacy laws. For further information about the safeguards used, please contact compliance@thomabravo.com.

Security

We are committed to protecting the personal information you entrust to us. We endeavor to implement appropriate security measures and technologies to seek to ensure the security of your personal information on our systems and to ensure that it is protected to the extent possible 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 process your personal data based on our instructions and they will be subject to a duty of confidentiality.

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

Notwithstanding our efforts to protect your information, no security system is completely impenetrable or error-free, so we cannot guarantee the absolute security of our databases, nor can we guarantee that information you supply to us will not be intercepted while in transit to us over the Internet. Any transmission of information or data by you to or through this Site is at your sole risk.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this privacy notice, 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 compliance@thomabravo.com.

Minors

This Site is only intended for individuals who are at least 18 years of age. We do not knowingly collect personal information from anyone under the age of 18 without parental consent. If a child under 18 has provided personally identifiable information to us through the Site, a parent or guardian may inform us at 1-800-221-0583 or compliance@thomabravo.com, and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this privacy notice.

Cookies

We use cookies in connection with the operation of this Site. A “cookie” is a piece of information sent to your browser by a website you visit. By choosing to use the Site after having been notified of our use of cookies in the ways described in this privacy notice, and, in applicable jurisdictions, through notice and acknowledgement of your consent, you agree to such use.

Necessary cookies used by the Site

Session Cookies: We use session cookies to provide you with the services available through the Site and to use some of their features. These cookies are served by Thoma Bravo and are essential for using and navigating the Site. Without these cookies, basic functions of the Site would not work. Because these cookies are strictly necessary to deliver the Site, you cannot refuse them without impacting how the Site functions. For example, when a visitor enters the Site using a mobile device, we detect the device and present the visitor with our mobile website (vs. our desktop website) for ease of navigation and content legibility.

These cookies are not essential for using and navigating the Site. However, without these cookies, certain functionality may become unavailable. You can block or delete these cookies by changing the browser settings.

Third-party cookies used by the Site

Analytics Cookies: The Site uses third-party analytics services, including, HubSpot and Google Analytics. These service providers use cookies to help the Site analyze how visitors use the Site. The information generated by the cookie about your use of the Site (including your IP address) are transmitted to and stored by our third-party service providers. Our third-party service providers use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Our third-party service providers also may transfer this information to third parties where required to do so by law, or where such third parties process the information on behalf of our service providers.

HubSpot Cookies: HubSpot, our site platform and hosting service, collects the information described above pursuant to their privacy policy, which is available at: legal.hubspot.com/privacy-policy.

CloudFlare Cookies: CloudFlare is a security utility that we use to help prevent and detect malicious visitors from entering our Site, while enabling legitimate users onto the Site. You can learn more about CloudFlare cookies and their functionality by visiting: https://support.cloudflare.com/hc/en-us/articles/200170156-Understanding-the-Cloudflare-Cookies.

Remarketing Cookies: Thoma Bravo and our third-party vendors (Google, Twitter and LinkedIn) may use cookies to periodically leverage remarketing functionality – to serve relevant information and/or ads while on other sites based on your past visit(s) to our Site.

Google

Google Ads (formerly “AdWords”) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

Twitter

Twitter remarketing service is provided by Twitter Inc. You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405. You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy.

LinkedIn

LinkedIn remarketing service is provided by LinkedIn. You can learn more about the privacy practices and policies of LinkedIn by visiting their Privacy Policy page: https://www.linkedin.com/legal/privacy-policy.

To block or delete cookies, or to withdraw your consent after accepting cookies, change the configuration of your browser to not accept cookies and delete any existing cookies.

For more information on cookies and the deletion of cookies, please visit: allaboutcookies.org.

Please note that if you limit the ability of the Site to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Your EU Rights

If you are located in the EEA or Switzerland, subject to applicable law, you may have the following rights in relation to personal information that we hold about you. To exercise these rights and controls, please contact compliance@thomabravo.com.

  • Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a reasonable fee, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
  • Correction: You may notify us of changes to such your personal information if it is inaccurate or it needs to be updated.
  • Deletion: If you think that we should not be holding or processing your personal information anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
  • Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
  • Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
  • Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
  • Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If you believe that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country. You can find details for your relevant EU national data protection authority at https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Your California Rights

If you are a natural person who is resident in the state of California, you may have the following rights in relation to personal information that we collect about you. To exercise these rights and controls, please contact 1-800-221-0583, compliance@thomabravo.com or using the Contact page of the Site (https://www.thomabravo.com/contact).

  • Disclosure: You have the right to request that we disclose to you, free of charge, the categories and specifics of the personal information we collect about you and/or, if applicable, disclose about you to a third party for business purposes (unless otherwise restricted). You may request the personal information up to 12 months preceding your request. Be advised that we are not required to disclose such information more than twice in as 12-month period. Note, Thoma Bravo currently does not and does not in the future intend to sell any personal information collected.
  • Deletion: You have the right to request that we delete the personal information we have collected from you that is in our possession or in the possession of our service providers, unless otherwise restricted by law or regulation.
  • Verifiable Request: We require a verifiable request from you to ensure that it is, in fact, you who is requesting such a disclosure or deletion. Once we verify the request, we will provide that information to you or delete the information.
  • Non-Discrimination: We follow the requirements of California Civil Code §1798.125 and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.

Currently the Site does not  recognize and respond to “do not track” signals. Should this change in the future, we will inform you through an updated version of this privacy notice.

Questions and Comments

If you have any comments or questions about our privacy practices or your experience with the Site, please do not hesitate to contact Thoma Bravo at 1-800-221-0583,  compliance@thomabravo.com or using the Contact page of the Site (https://www.thomabravo.com/contact).