Online Privacy Policy

Last Updated: May 7, 2021

This Online Privacy Policy (“Policy”) applies to this Golub Capital (“Company”) website www.golubcapital.com (our “Website”). The term “Golub Capital” or “we” or “us” or “our” in this Policy refers to Golub Capital and its affiliates.

This Policy describes the types of information we may collect from you or that you may provide when you visit the Website and our practices for collecting, using, maintaining, protecting and disclosing that information. This Policy applies to information we may collect on the Website. This Policy does not apply to information collected by any third parties, including through any application or content that may link to or be accessible from, or on, the Website. This Policy also does not apply to information that may be collected by us offline or through any other means, including on any other website operated by Golub Capital or any third party.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you should not use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Collecting and Using Information

Information We May Collect Online

We collect information about you in various ways. For example, you may provide information directly to us or we may collect certain information about you automatically through your use of our Website. Some of the information you provide to us or that we collect is “personal information.” The personal information that you provide and that we collect or receive from you depends on the context of your interaction with us and our Website, the choices you make when you use our Website, and the products and features that you use.

Information You Provide To Us

When you interact with us through our Website, you may provide information to us directly. For example, you provide information to us when you express an interest in obtaining information about us or our products or services, communicate with us or complete contact information or other forms on our Website.

Some of the information you provide to us may, for example, include the following:

• Name and contact details. This includes information such as your address, email address, telephone number, and social security number.

Information We Collect Automatically

When you use our Website, we may automatically collect certain information about you. Automatically collected information may, for example, include the following:

• Your IP address or mobile device identifier.
• The type of browser and operating system you are using.

• The domain name of your Internet service provider.
• Information collected via cookies and other tracking technologies. This includes information about the content you view and the features you access on our Website. For more information see “Online Tracking and Advertising” below.

• Information regarding when you access and how you use our Website. This includes information regarding the duration of your engagement with certain aspects of the Website.

This information may be combined and linked with information from other sources.

How We May Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To reach out to you about and market or promote new information to you.
• To communicate with you and notify you about changes to our Website or any products or services we offer or provide though it.
• To help us improve our Website and deliver a better and more personalized experience. This includes by enabling us to estimate and analyze our audience size and usage patterns, store information about your preferences, speed up your searches and recognize you when you visit our Website.
• To deliver targeted and other advertising to you. Please see “Online Tracking and Advertising” and “Third-party Use of Cookies and Other Tracking Technologies” below for further information about our and third parties’ use of cookies and other tracking technologies to provide you with relevant ads on our Website and other sites, and information about how to disable cookies and make other choices related to targeted advertising.
• To carry out our obligations and enforce our rights arising from any contracts entered into with you. This includes for billing and collection, and as we believe is necessary or appropriate to protect, enforce or defend the legal rights, privacy, safety or property of the Website, its employees or agents, or other users or to comply with applicable law.
• For our legitimate interests and in any other way we may describe when you provide the information or otherwise at your direction or with your consent.
• We use information as otherwise described or permitted by law or as we may notify you.

How We May Share Your Information

We may share information that we collect about you or that you provide to us, including any personal information, with the following parties:

• With our affiliates.
• With employees in order to respond to your requests or questions.

• With third parties, including those who perform services on our behalf, for example, with our vendors. We may also share information with companies that operate our websites, provide web analytics, data processing, advertising, email distribution, marketing, payment processing and other services. These third parties may use your information as is necessary or appropriate for the performance of the services they provide to us, or as otherwise contractually permitted.
• When you request any of our products or services. We will share your information to the extent necessary to fulfill your request.
• If we think we have to in order to comply with the law or to protect ourselves.

• With any successor to all or part of our business. For example, in the event of a merger, acquisition, divestiture, change of control or liquidation of Golub Capital or part of its business (or in anticipation of such an event) we may share that information as part of or in contemplation of that transaction.
• For other reasons we may describe to you or as permitted by law.

We may also disclose your information to comply with any court order, law or legal process, including to respond to any government or regulatory request.

Online Tracking and Advertising

We and service providers or partners we engage may use cookies, tracking pixels, web beacons and other similar technologies to automatically collect certain information that allows us to understand usage of the Website, improve our content and offerings, and deliver advertisements in which you might be interested. Information collected automatically may include information about your Internet connection, the equipment you use to access our Website, browser information, usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies. We may also automatically collect information about your visits to our Website, including traffic data, location data, logs and other communication data, and the resources that you access and use on our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse Flash objects, please note that some parts of this Website may then be inaccessible or not function properly.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us to, for example, count users who have visited those pages and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

We may use this automatically collected information to help us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

• Help us or ad networks understand what ads you have seen or to otherwise target advertising to you.

Our website may use Google Analytics, a web analytics service offered by Google. You may learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy at http://www.google.com/policies/privacy/partners.

Your Choices

Please click Manage Cookies to manage cookies. If you opt-out of cookies using this tool, an “opt-out” cookie will be placed on your device. Opt-out cookies are device- and browser-specific, meaning that you must opt-out across all of your devices and browsers. If you clear your cache or delete cookies from your browser, the opt-out cookie will also be deleted, meaning you will need to opt-out again.

In addition, you can generally manage your cookie preferences through your web browser. Most web browsers will tell you how to stop accepting new cookies and how to disable existing cookies. For more information regarding how to manage your preferences, please consult the information made available by your particular browser or visit www.allaboutcookies.org. With respect to Google Analytics, you can also view Google’s currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

Please note that if you choose not to accept cookies, you may miss out on certain features of our Website.

Third-party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website may be served by third-parties, including third party advertising networks. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising and display ads or other targeted content that is believed to be relevant to you.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Social Media and Other Platforms

You may be able to access social media networks like Facebook, LinkedIn or Instagram (“Social Media Platforms”) directly or indirectly through our Website. You may also have the option of posting your activities on Social Media Platforms, tagging our brands, or posting content to pages we maintain on Social Media Platforms. As a result, we may collect information from or about you via Social Media Platforms. If you choose to make any of your activities or other content available through a Social Media Platform, including on our pages, or you engage in other activities in connection with a Social Media Platform, your friends and followers on those Social Media Platform that you have enabled, and potentially the general public, will be able to view those contributions and activities. Please remember that the manner in which Social Media Platforms use, store, and disclose your information is governed by the policies of such third-parties. We are not responsible for the privacy practices or other actions of any Social Media Platforms that may be enabled via our Website.

Links to Third Party Websites

Our Website contains links to third party sites and services whose privacy practices may be different than ours. We also allow you to connect with other third-party sites and services. We are not responsible for the privacy practices of third-party sites and services and you should consult the other third-party sites’ and services’ privacy notices in order to better understand their privacy practices.

Additional Information

Data Security 

We have implemented measures designed to secure your information from accidental loss and from unauthorized access, use, alteration and disclosure.

Transfers Overseas

You acknowledge that we are U.S. entities and that your information will be stored within the United States and not necessarily in the country of your residency. In particular, your information may be transferred anywhere that we have our servers or our activities. This Website is subject to U.S. laws, which may not be afforded the same level of protection as those in your country.

Changes to Our Policy

It is our policy to post any changes we make to our Policy on this page with a notice that the Policy has been updated on the Website home page. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Policy to check for any changes.