TWG Global Partners Privacy Notice

Effective Date: May 2024

Who We Are

This Privacy Notice describes the data protection practices of TWG Global, LLC for visitors to the website where this Notice is posted. TWG Global, LLC as used herein refers to the affiliated investment, securities and other businesses of TWG Global, LLC (collectively, “TWG Global,” “we,” “us,” or “our”).

TWG Global, LLC is the data controller for your information. TWG Global affiliates who are also controllers of certain of your information are listed here applicable to:

visitors to www.twgglobal.com (“our websites”);
and any person (other than employees) whose personal data is processed by a member of the TWG Global corporate group in the course of business or other commercial interactions with the group (unless, and to the extent that, a separate privacy notice has been provided to you in which case that notice will take precedence).

Application of This Privacy Notice

Certain affiliates of TWG Global have their own privacy policy with respect to their business or practices. Such policy will apply to information collected specifically by such entity only. Except as noted above, this Privacy Notice applies to anyone who visits or uses TWG Global’s websites where this Policy is posted or otherwise provides personal data to TWG Global in the course of business with TWG Global. Investors in funds are subject to separate privacy practices which are delivered to them on an annual basis pursuant to applicable laws. Depending on your location and the nature of your interactions with members of the TWG Global group, other members of the corporate group may act as data controllers in respect of your personal data (either in addition to or instead of the aforementioned entities). Please contact us if you would like further information about the members of the TWG Global corporate group that act as data controllers in respect of your personal data. In this Privacy Notice, ” TWG Global, “we,” “us” and “our” include such members of the TWG Global, LLC corporate group.

The Information We Collect and How We Use it

We may obtain information about you through the means listed below. Please note that we may need certain types of information so that we can provide certain services to you (including full use of our websites). If you do not provide us with such information, or ask us to delete it, we may be unable to provide you with such services and you may no longer be able to access or use certain parts of our websites.

1. Information You Provide to Us

If you provide TWG Global or affiliates with your personal information (whether through our websites or otherwise), we will collect that information. This could include identifying contact information, such as your name and email address, as well as any other information you choose to provide when you contact us.

We use individual contact information for our business purposes, including to:

Respond to your requests or questions. For example, we might use your information to respond to your customer feedback, to send you newsletters that you have requested, and/or to provide you with more effective and efficient customer service.
Improve our websites, products and services. For example, we may use your information to make our websites and products better. We might use your information to customize your experience with us, customize content on our websites, and help us better understand your interests and needs so that we can improve our websites.
Secure our websites and related services. For instance, we may use your information to protect TWG Global and our customers and potentially third parties, if necessary.
Communicate with you. For example, we may contact you about your feedback, this Privacy Notice, and/or to enroll you in or unsubscribe you from an email newsletter.
Customize the advertising or content that you see on our websites.
Help us better understand your interest and needs and improve the websites, including through research and reports, and to test and create new website features and services.
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
Establish, exercise or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

2. Information We Collect Through Automated Means

When you use our websites, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting certain network activity and device usage information about you through automated means. Where required by applicable laws, we seek your consent to collect your personal information through automated means.

We do not use your personal data for the purposes of automated decision making.

Websites. When you use our websites, we may collect and analyze information network activity and device usage information, such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the websites, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on our websites, the date and time you used the websites and upload or post content, error logs, and other similar information.

We and our service providers may use network and device usage information for our or our service providers’ business and operational purposes, including to:

Improve our websites, products and services as described above.
Secure our websites and related services and described above.
Customize the advertising or content that you see on our websites.
Help us better understand your interest and needs and improve our websites, including through research and reports, and to test and create new website features and services.
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
Establish, exercise or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

Location Information

When you use our websites, we and our service providers may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device.

We and our service providers may use location information for our or our service providers’ business and operational purposes, including to:

Improve our websites, products and services as described above.
Secure our website and related services as described above.
Customize the advertising or content that you see on the websites.
Help us better understand your interest and needs and improve our websites, including through research and reports, and to test and create new website features and services.
Comply with any procedures, laws, and regulations (including, without limitation, in relation to verification and “Know Your Customer” checks) which apply to us where it is necessary whether for our legitimate interests or the legitimate interests of others, or otherwise.
Establish, exercise or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

3. Information We Collect from Others

We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, social media platforms and other parties that we may attribute to you based on your assignment to certain statistical groups. We and our service providers may use this information for our and our service providers’ business and operational purposes, including to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, advertising, and products.

Online Analytics and Marketing

1. Analytics

We may use third-party web analytics services (such as those of Google Analytics) on our websites to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

If you receive an email from us we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

2. Marketing

Our websites may integrate third-party marketing technologies that allow for the delivery of relevant marketing content to visitors to our websites and recipients of our emails. This content may be based on various factors such as the content of the page you are visiting, your searches, demographic data, user-generated content, interaction with email newsletters you receive, and other information we collect from you.

To provide the marketing content discussed above, third parties may place cookies or other tracking technologies on your computer, mobile phone, or other device.

We neither have access to, nor does this Privacy Notice govern, the use of cookies or other tracking technologies that may be placed on your device you use to access our websites by third parties that are not affiliated with us. If you are interested in more information about how you can generally control cookies from being put on your device, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or if you are resident of a Member State located in the EU, Your Online Choices to opt-out of certain tracking cookies being put on your device. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Information We Collect and the Ways We Use It

Disclosure of Data: TWG Global may share the information we collect as described above in the following ways:

Affiliates and Subsidiaries. We may share information we collect within the TWG Global family of companies to deliver products and services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.
Service Providers. We provide access to or share the information we collect with select third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, and legal services.
Protection of TWG Global and Others. We may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of TWG Global, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) the information that we collect may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
Aggregate/Anonymous/Deidentified Information. From time to time, we may share Aggregate/Anonymous/Deidentified Information about use of our websites, such as by publishing a report on usage trends. Where such information is fully anonymized, the sharing of such data is unrestricted.

Combined Information: For the purposes discussed in this Privacy Notice, we may combine the information that we collect through our websites with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Notice.

Aggregate/Anonymous/Deidentified Data: We may aggregate, anonymize and/or deidentify any personal data we hold so that such information can no longer be linked to you or your device (“Aggregate/Anonymous/Deidentified Information”). We may use Aggregate/Anonymous/Deidentified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors. For the avoidance of doubt, to the extent any Aggregate/Anonymous/Deidentified Information is not fully anonymized, such information shall still be your personal data and shall be processed by us in accordance with this Privacy Notice.

Retention of Your Information

We keep the information we collect for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

Data Subject Rights and Your Choices

You have certain rights with respect to your information as further described in this section.

Legal rights for users who are located in the European Union or United Kingdom

If you are located in the EU or the UK, you have the right to request that we:
- Provide access to and/or a copy of certain information we hold about you
- Prevent and/or stop the processing of your information for certain purposes (including for the purpose of direct marketing)
- Update information which is out of date or incorrect
- Delete certain information which we are holding about you
- Restrict the way that we process and disclose certain of your information
- Transfer your information to a third-party provider of services
- Revoke your consent for the processing of your information
If you would like to exercise your rights (or would like further information about your rights), please contact us via email at info@twgglobal.com.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

You have the right to make a complaint to:
- if you are located in the EU, the data protection supervisory authority of the member state in which you are located; or
- if you are located in the UK, the Information Commissioner’s Office (at https://ico.org.uk/make-a-complaint/data-protection-complaints/data-protection-complaints).
Marketing Communications and Sharing for All Users

You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as set out in this Privacy Notice and as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications.

Third Party Links and Features

Our websites contain links to third-party websites such as social media sites. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Notice. We urge you to read the privacy and security policies of these third-parties.

Children’s Privacy

Our websites are intended for general audiences and not for children under the age of 16. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, or from children under the age of 16, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU or UK residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU or UK resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

Transfer of Personal Data

Your information will be processed for the purposes described herein. As described above, we also may subcontract the processing of your data to, or otherwise share your data with, other members within TWG Global and its affiliates, service providers, and business partners in other countries (including countries outside of the United States, the UK and the EEA), in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of the website to you and the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to third party information processors, we will take appropriate measures to ensure such companies protect your information adequately and in accordance with applicable law. These measures may include entering into an appropriate data transfer mechanism in accordance with EU, UK and/or other data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as detailed in the “Contact Information” section below.

How We Protect Your Information

TWG Global takes technical and organizational security measures to protect the information provided via the websites from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to TWG Global via the Internet.

California Privacy Rights

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities to which we share such information in the INFORMATION WE COLLECT AND HOW WE USE IT, the HOW WE SHARE AND DISCLOSE YOUR INFORMATION, and the other above sections of this Privacy Notice.

CCPA Rights. California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you may request that we:

provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Privacy Notice.
provide access to certain information we hold about you;
delete certain information we have about you; and/or
provide you with information about the financial incentives that we offer to you, if any.

California residents can also designate an authorized agent to make such requests on their behalf.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law, such as business contact information. In addition, we need certain information in order to provide the websites to you.

We will take reasonable steps to verify your identity before responding to a request. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us via email at info@twgglobal.com.

Sale or Sharing of personal information. California privacy law sets forth certain obligations for businesses that “sell” personal information. Pursuant to the definition of “sell” or “share” under the CCPA and current guidance, we do not engage in such activity and have not engaged in such activity in the past twelve months, including for minors under 16 years of age without affirmative authorization.

Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Privacy Information for Nevada Residents
Under Nevada law, certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident and you have purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by email to info@twgglobal.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice at any time to reflect changes in the law, our data collection and use practices, the features of our websites, or advances in technology. We will make the revised Privacy Notice accessible through the websites, so you should review the Privacy Notice periodically. You can know if the Privacy Notice has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the websites, you are confirming that you have read and understood the latest version of this Privacy Notice.

Contact Information

Please feel free to contact us if you have any questions about this Privacy Notice or our information practices. You can reach us via email at info@twgglobal.com.