Genstar Capital (“Genstar” or the “Firm”) recognizes the importance of, and is committed to, maintaining the privacy of personal information that it receives relating to individuals. This Privacy Policy seeks to helpyou understand whether and how we collect Personal Information from or about you when you visit this website (the “Site”), and how we may use, share, and retain such information. The term “Personal Information” has the meaning given to it under applicablelaws and regulations relating to data protection and privacy (including similar terms such as “personal data”) and, for the avoidance of doubt, refers to any information which directly or indirectly identifies or otherwise relates to a living individual or household. California residents click here to read our California Privacy Policy.

Your visit to the Site is subject to this Privacy Policy, which is incorporated into our Terms of Use. This Privacy Policy does not concern any third-party website to whichthe Site may link. Note, if you are a Genstar investor, our policies and practices regarding the collection and processing of your Personal Information (including through the LP Login function of the Site) are detailed in our Investor Privacy Notice. If you are a Genstar employee, you will have separately received our Employee Privacy Notice.

  1. The InformationWe Collect About You

    We may collect the categories of Personal Information listed below about you in connection with your access and/or use of the Site.

    • Communications Data. We may collect Personal Information that you provide when you contact us for any reason, such as to express an interest in obtaining additional information about our services, or direct questions or concerns about our services to us.
    • Information Collected by Cookies. Our Site may use cookies to collect information about the services that you use and how you use them, which may include device-specific information, your navigation throughout the Site, and other technical and browsing preferences including your location and entry point to the Site. We may use both Session Cookies and Persistent Cookies: a Session Cookie disappears after you close your browser; a Persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent Cookies can be removed. Please review your web browser’s “Help” file to learn the proper way to modify your Cookie settings.
    • Technical Information. We may automatically receive and record technical information from your computer, web browser and/or mobile device, including your IP address or other device address or ID, web browser and/or device type, hardware and software settings and configurations, the web pages or sites that you visit just before or just after visiting the Site, the pages you view on the Site, your actions on the Site, and the dates and times that you visit, access, or use the Site. This includes information about how you use and navigate the Site, including which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions with the Site (together, “Usage Data”).
  2. How We Use Your Information

    Your Personal Information may be collected, stored, disclosed and processed by Genstar for the following purposes:

    • To operate, maintain, enhance, and provide all of the features of the Site;
    • To personalize the Site, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Site;
    • To understand and analyze the usages trends and preferences of our users, to analyze and report on the Site’s traffic, marketing and usage trends, to improve the Site, and to create new features and functionality;
    • For ongoing review and improvement of the information, content and services provided on the Site to ensure it is user friendly;
    • To conduct analysis required to detect malicious data and understand how this may affect your IT system;
    • For in-depth threat analysis, toprevent any potential disruptions such as cyber-attacks, and for statistical monitoring and analysis of current attacks on devices and systems for the on-going adaption of the solutions provided to secure systems and devices against current attacks;
    • To provide you with our products and services, and to allow you to use and access functionality provided by the Site;
    • To inform you about news and information relating to our business and services (generally, you can opt-out of receiving promotional communications through links provided in the messages or by contacting us directly using the contact information provided below in Section 8);
    • To detect, investigate and prevent fraud and other crimes or malpractice, and to improve fraud detection and information security;
    • For the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), and to obtain legal advice or to establish, exercise or defend legal rights;
    • For the management and administration of our business, and to comply with our contractual obligations; and
    • For purposes otherwise set out in this Policy.

    Genstar is entitled to use your Personal Information for these purposes because one or more of the following legal bases applies:

    1. Genstar needs to do so in order toperform its contractual obligations to you (for example, in order to manage your investments and verify the information you provide);
    2. Genstar has obtained your specific and informed consent (which may include written consent) unless an exemption provided under applicable law permits the use and disclosure of your Information without your consent;
    3. Genstar has legal or regulatory obligations that must be discharged;
    4. Genstar may need to do so in order to establish, exercise or defend its legal rights or for the purpose of legal proceedings; or
    5. the use of your Information is necessary for our legitimate business interests or the legitimate interests of a third party, provided such interest are not overridden by your rights or interest, including (i) allowing Genstar to effectively and efficiently administer and manage the operation of its business; (ii) maintaining compliance with internal policies and procedures; (iii) monitoring the use of our copyrighted materials; (iv) offering optimal, up-to-date security solutions for mobile devices and IT systems; or (v) for internal research purposes.

    If you are located in a jurisdiction which requires us to obtain your consent to collect, use, store, process and disclose your Personal Information, you understand that by accepting the terms of this Policy you expressly provide your consent to Genstar collecting, using, storing, processing and disclosing your Personal Information as set out in this Policy.

  3. When We Disclose Information

    Genstar does not share Personal Information with other people or nonaffiliated companies except when we have your permission, as required by law, and/or under the following circumstances:

    • We work with third party service providers to provide website development, hosting, data storage, maintenance, and other services for us. To the extent it is necessary for these third party service providers to complete their contractual obligations to us, these third parties may have access to or process information about you.
    • We partner with certain third parties to collect information regarding your use of our products and services in order to improve the maintenance and support we are able to provide you for our products and services. These third parties may also engage in analysis, auditing, research, andreporting and may use web logs or web beacons, and they may set and access Cookies on your computer or other device. If you prefer to prevent third parties from setting and accessing Cookies on your computer, you may set your browser to block Cookies. Please note that certain aspects of our Site may not work correctly if you block Cookies. Any third party plugins and components are governed by the privacy policy of the company providing them (and not this Policy), so we advise you to read their privacy statements.
    • In some cases, in order to provide the products and services available through and/or in connection with the Site, we provide information about you to trusted partners who work on behalf of or with us under confidentiality agreements.
    • We may partner with third parties to manage our advertising on other websites. Our third party partners may use tracking technologies to gather information about your activities on our Site and other websites to provide you with advertising based on your browsing activities and interests.
    • We may share information about you in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims.
    • We may share information about you in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
    • We may transfer or assign information about you if Genstar is acquired byor merged with another company, or in the unlikely event of a bankruptcy.
  4. Your Rights

    Depending on the jurisdiction in which you reside, you may have legal rights in relation to your Personal Information. These rights may include:

    • Declining to share certain information with us (in which case we may not be able to provide to you some of the features and functionality of the Site);
    • Requesting and obtaining information regarding how Genstar may use your Personal Information;
    • In some circumstances, requestingand receiving some Personal Information about you that you have provided to Genstar;
    • In some circumstances, requesting that Genstar correct your Personal Information if it is inaccurate or incomplete;
    • In some circumstances, requesting that we erase your Personal Information (but please note that there may be circumstances where we are legally entitled to retain Personal Information regardless of any such request);
    • In some circumstances, requesting that we restrict or block our processing of your Personal Information (again, there may be circumstances where we are legally entitled to refuse that request); and
    • Where applicable, the right to lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have beeninfringed by Genstar.

    You can inquire about your rights by contacting us using the details listed below in Section 8.

  5. How We Protect Your Information
    • Data Security. Genstar maintains physical, electronic and procedural safeguards designed to protect the integrity and security of your information. We cannot, however, ensure or warrant the security of any information you transmit to us through the Site and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Although we may allow you to adjust your privacy settings to limit access to your information, no security measures are perfect or impenetrable. We cannot control the actions of other users or other third parties with whom you may choose to share your information. Therefore, we cannot and do not guarantee that information you post through the Site will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
    • Data Retention. We only store your information for as long as may be needed to provide services to you, with the exception of information that we may need to store for a longer period of time to comply with legal or regulatory obligations, resolve disputes, enforce our agreements, or for records management purposes. Genstar will also retain Usage Data for internal analysis purposes.
    • Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods. Even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.
    • Protecting Children. Our Site and our products and services are intended for use by those over the age of 18. We do not knowingly collect personal information from children under the age of 18. If you are under 18 years of age, then please do not use or access the Site at any time or in any manner.
  6. International Visitors

    This Site is controlled and operated by Genstar in the United States. If you choose to access the Site from outside the United States, you acknowledge that you will be transferring your information, including Personal Information, outside of those regions to the United States for storage and processing, as necessary to provide to you the products and services available through the Site and you consent to such transfer.

  7. Other Important Information
    • Changes and Updates to this Privacy Policy. We reserve the right to make changes to this Privacy Policy at any time. We will notify you about significant changes in the way we treat your information, including by placing a prominent notice on the Site or by sending you an email so that you can choose whether to continue using the Site. Material modifications are effective 30 calendar days after our initial notification or upon your acceptance of the modified Policy. Immaterial modifications are effective upon posting of the updated Privacy Policy on the Site. Please revisit this page periodically to stay aware of any changes to this Privacy Policy. For the avoidance of doubt, disputes arising hereunder will be resolved in accordance with the Privacy Policy in effect at the time the dispute arose.
    • Governing Law. This Privacy Policy is governed by California state law. Any dispute regarding this Privacy Policy or your use of the Site shall be resolved solely in the state or federal courts located in California.
    • Limitation of Liability. By accessing the Site and/or providing us with Personal Information and other data, to the extentpermitted by applicable law, you expressly and unconditionally release and hold us harmless from any and all liability for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of such information. In addition,while we take efforts to ensure the proper and appropriate use of data by our service providers that may receive your information from us, we are not responsible for any injuries, loss, or damage of any kind arising from or in connection with the use and/or misuse of your information caused by those service providers.
    • Third Party Websites. The Site may provide links to, or features from, other third party websites. If you link to or use such third party sites or features, you do so at your own risk. We donot control and are not responsible for the content or practices of any third party website, application, or other product or service.
  8. Our Contact Information

    If you have any questions about the Firm’s Privacy Policy or our practices in relation to your Personal Information, you may contact us at privacy@gencap.com.

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