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
Personal Information We May Collect Online
As used in this Policy, “Personal Information” means information by which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, assets, income, net worth and copies of financial documents. You may provide such Personal Information to us directly, such as when you complete contact information or other forms on the Website.
How We May Use Your Personal 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 notify you about changes to our Website or any products or services we offer or provide though it.
- In any other way we may describe when you provide the information.
- We use information as otherwise described or permitted by law or as we may notify you.
How We May Share Your Personal 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 who perform services on our behalf, for example, with our vendors. We may also share information with companies that operate our websites.
- 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 that transaction.
- For other reasons we may describe to you or as permitted by law.
We may also disclose your Personal Information to comply with any court order, law or legal process, including to respond to any government or regulatory request.
Other Information We May Collect Online and How We May Use It
Other Information is any information other than Personal Information, such as information collected automatically as you navigate through our Website. 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:
- 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).
The information we collect automatically is statistical data and does not include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. 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.
“Do Not Track” Signals
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard for responding is established, we may revisit our policy on responding to these signals.
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.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.
California Privacy Rights
If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please write, call or send an email to the below contact information.
You acknowledge that we are U.S. entities and that your Personal Information will be stored within the United States and not necessarily in the country of your residency. In particular, your Personal 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.
For Residents of the European Economic Area
For users within the European Economic Area (the “EEA,” including users within the European Union), we may transfer data from the EEA to data centers located in the United States for processing, pursuant to your specific consent or in connection with the carrying out of a contract we have with you (and in that case, pursuant to GDPR-compliant Standard Contractual Clauses that safeguard your information). Such transfer and processing will be performed in accordance with Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and free movement of such data, known as the General Data Protection Regulation (“GDPR”). This includes the imposition of required safeguards with respect to accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of data.
If you are a resident of the EEA, you have the right to the following, as applicable under the GDPR, provided no exceptions or qualifications apply:
- The right to access. You have the right to request copies of your personal data.
- The right to rectification. You have the right to request correction of any of your personal data that you believe is inaccurate. You also have the right to request that we complete personal data that you believe is incomplete.
- The right to erasure. You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing. You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing. You have the right to object to our processing of your personal data, under certain conditions.
- The right to data portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you believe we are unlawfully possessing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find contact details here: https://edpb.europa.eu/about-edpb/board/members_en.
If you make a request, we will respond within thirty days. If you would like to exercise any of these rights, please contact us at our email email@example.com. Your exercise of these rights may affect your ability to continue to access and/or use this Golub Capital Portal.
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.
To ask questions about this Policy and our privacy practices, contact firstname.lastname@example.org.