VCM FUND ADVISORS, LLC

Privacy and Cookie Notice

Effective Date:  February 16, 2023

Contents

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

a. What You Give Us

b. Information from Use of the Site

c. Data about Children

2. HOW DO WE USE THE INFORMATION WE COLLECT FROM YOU?

3. WITH WHOM DO WE SHARE YOUR INFORMATION?

4. COOKIES AND OTHER PASSIVE COLLECTION TECHNOLOGIES

5. SECURITY

6. DATA RETENTION

7. YOUR RIGHTS AND CHOICES

8. LINKS TO THIRD PARTY SITES

9. UPDATES AND CHANGES TO OUR PRIVACY POLICY

10. HOW TO CONTACT US

VCM Fund Advisors, LLC, (collectively with its affiliates, “Versa”, “we”, or “us”) respect and value your privacy. As part of our commitment to use the information you share with us responsibly, we want you to be familiar with how we collect, use, and disclose information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information”).

This Privacy and Cookie Notice (this “Notice”) describes how we process Personal Information about you that we collect through the website, www.versa.com, from which you are accessing this Notice (the “Site”). This Notice does not apply to information that we collect offline, such as over the telephone or in person. By using the Site, you agree to the terms and conditions of this Notice, including our Terms of Use do not agree with any part of this Notice, you are not authorized to use the Site.

1. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

a. What You Give Us

Versa may electronically collect Personal Information from you when you submit it to us through the Site. Some parts of the Site may ask you to submit Personal Information in order for you to benefit from the specified features or to participate in a particular activity. For example, you may voluntarily provide Personal Information to us in the following ways:

  • Contact Us Links:  If you contact us through any of our contact links or a contact email, such as info@versa.com, available on the Site, we collect the information that you provide through these links or emails.  Similarly, if you ask for more information about a product or service on the Site, we collect the Personal Information you provide to contact you with that information.

  • Employment Applications:  Some areas of the Site may allow you to submit information related to career opportunities with Versa or certain affiliate companies (e.g., portfolio companies). If you apply for an employment opportunity through our Site, including by emailing us at careers@versa.com, you may provide us with certain Personal Information about yourself (such as information contained in a resume, cover letter or similar employment-related materials, or any applicable pre-screening questions).

b. Information from Use of the Site

Through your use of the Site, we may also gather information about your use of the Site that does not identify you directly but may identify your computer or device. Generally, this information is collected through what we refer to herein as “Traffic Data.” We may collect and store such Traffic Data automatically whenever you interact with the Site. For example, we may collect your IP address, the hostname of your computer, browser information and reference site domain name every time you use the Site. We may collect information regarding user traffic patterns and Site usage. This Traffic Data is used to analyze and improve the Site and to provide you with a better experience on the Site. Please see Section 4 below in this Notice for more information about our use of cookies and other technologies.

c. Data about Children

We do not knowingly collect Personal Information through the Site from children under the age of 13. We reserve the right to delete any information identified as having been provided through the Site from children under the age of 13.

2. HOW DO WE USE THE INFORMATION WE COLLECT FROM YOU?

We use Personal Information submitted by you or otherwise collected through the Site for the purposes described in this Notice and as otherwise described to you at the point of collection. Generally, we use the information you provide for the reason for which it was provided. For example, if you contact us by e-mail, we will use the Personal Information you provide to answer your question or resolve your problem and will respond to the email address from which the contact came. We may also use Personal Information about you as specifically described below:

  • Requests, Inquiries, and Applications:  We may use your Personal Information to process, evaluate, and respond to your requests, inquiries, and applications.

  • Manage Our Relationship with You: We may use your Personal Information to send you important information regarding our relationship with you or regarding the Site, such as information about changes to our terms, conditions, policies, and other administrative information, or about changes to your account.

  • Internal Business Purposes:  We may use your Personal Information for internal business purposes, including without limitation, to help us operate, evaluate, and improve the quality of the Site; to better understand those individuals that utilize the Site; to verify your identity; to prevent, protect against, identify, or address fraud, unauthorized activity, claims, liabilities, and other wrongdoing; to provide you with customer service, resolve disputes, and enforce our terms and policies; and to generally manage our business.

  • Employment:  If you provide Personal Information to apply for a job with Versa, our affiliates, or portfolio companies through the Site, we may use the Personal Information you provide to evaluate your job application, consider you for that job or for similar jobs in the future, and contact you regarding possible employment.

  • Analytics:  We may use Traffic Data to performing market research and data analytics. To learn more about how we use Traffic Data, please see Section 4 of this Notice.

  • Legal Requirements, Industry Standards, and Contractual Obligations:  We may use your Personal Information for complying with and enforcing applicable legal requirements, industry standards, and our contractual obligations.

  • Changes of Control:  We may use and transfer information, including your Personal Information, as part of an acquisition or liquidation, namely if we are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company, or if we undergo liquidation or bankruptcy proceedings.

We may use non-Personal Information or aggregate information that does not identify an individual without restriction, and we may share such information with third parties.

3. WITH WHOM DO WE SHARE YOUR INFORMATION?

We may share your Personal Information only as described in this Notice or as otherwise described to you at the point of collection.    

  • Affiliates: We may share your Personal Information with our affiliates for purposes consistent with this Notice. Our affiliates will be bound to maintain that Personal Information in accordance with this Notice.

  • Agents, Consultants, and Service Providers: We may share your Personal Information with individuals or companies that we hire to provide services to us, such as website hosting services or data analytics services, or to provide functionality to the Site.

  • Third Party Business Partners: Certain services accessible through the Site are made available through third party business partners. Although our treatment of your Personal Information that is provided through the Site is governed by this Notice, any information provided through websites, applications, or other online features operated or controlled by these third-party business partners will be governed by the privacy policies of such third parties.

  • Business Transfers:  We may transfer your Personal Information in the event of a business sale, merger, consolidation, change in control, transfer of substantial assets, bankruptcy, liquidation, or reorganization. We may also disclose your Personal Information in the course of due diligence of such a transaction. You acknowledge and agree that any successor to or acquirer of Versa (or its assets) will continue to have the right to use your Personal Information and other information. Whether the recipient of your Personal Information in these cases will handle your Personal Information pursuant to this Notice will depend on the applicable law and other factors.

  • Legal Requirements:  We use and disclose Personal Information as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

  • Passively Collected Information: We may share Traffic Data that does not identify you directly, but may identify your computer or device, as described in Section 4 of this Notice.

4. COOKIES AND OTHER PASSIVE COLLECTION TECHNOLOGIES

As you navigate the Site, certain Traffic Data may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:

Using cookies: Like many companies, our Site may use “cookies” to help make sure the Site is meeting the needs of its users and to help us make improvements. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies set by us on the Site to tell us, for example, whether you have visited us before or if you are a new visitor.  We use third-party cookies set by our service provider, Google Analytics, to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site.  We do not use data collected by cookies to identify who you are.  We also do not use cookies for interest-based advertising.

You can visit https://www.google.com/analytics/learn/privacy.html to learn more about Google Analytics’ use of cookies.  You can visit https://tools.google.com/dlpage/gaoptout for information on how to opt out of Google Analytics cookies.

You can refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies, you may not be able to access all or parts of our Site or functionality may be limited. Please see the following links for more information with respect to how you can block or erase cookies via your particular browser: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera. Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers.

Social Media Plug-Ins:  We use social media plug-ins from social media networks like LinkedIn, which are labeled on our Site with the well-known symbols of the respective social network. If you interact with these plug-ins, your activity on the Site may also be made available to those social networks. In order to understand how those social networks use and disclose your Personal Information, please review the privacy policies available on the websites of those social networks.

Do Not Track Signals:  Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Notice whether or not a DNT signal is received.

Although our use of passive collection technologies may change over time as technology evolves, the above descriptions are designed to provide you with additional detail about our current approach to information collected from passive technologies.

5. SECURITY

We take reasonable steps to protect the Personal Information collected by us from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration, and destruction. However, no network, server, database, or Internet or e-mail transmission is ever fully secure, error-free, or “hacker proof.” Therefore, you should take special care in deciding what information you provide to us. Please keep this in mind when disclosing any Personal Information.

6. DATA RETENTION

We generally retain Personal Information for so long as it may be relevant to the purposes above, or for longer when required by law. To dispose of Personal Information, we may anonymize it, delete it, or take other appropriate steps. Even if we delete your Personal Information, it may persist on backup or archival media for an additional period of time for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

7. YOUR RIGHTS AND CHOICES

Opt Out from Cookie-Related Processing: You can opt out from certain cookie-related processing as described in Section 4 of this Notice.

Opt Out of Promotional Emails: Where it is in accordance with your preferences, Versa may send you communications by email. You may “opt out” of receiving promotional emails by following the instructions in the message that you receive, or by sending an e-mail to info@versa.com indicating which communications you no longer wish to receive. Note that we may still send certain administrative messages to you by email, where permitted by applicable law.

California Residents: California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about their Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not currently disclose your information to third parties for their direct marketing purposes.

8. LINKS TO THIRD PARTY SITES

The Site may contain links to other websites for the convenience of users in locating information or services that may be of interest, such as links to area hotels or informational resources about our industry. Additionally, certain features on the Site may redirect you to a site controlled by a third-party service provider. For example, clicking on the “Limited Partners” login button on the Site will redirect you to our third-party service provider’s platform in order to access your Site account.

If you access a third-party website from a link on the Site, any information you disclose on that website is not subject to this Notice. It is possible that these links may be used by third parties or others to collect personal or other information about you. Regardless of appearance or shared branding, Versa does not endorse and is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites. Versa does not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

9. UPDATES AND CHANGES TO OUR PRIVACY POLICY

The business and operations of Versa may change from time to time. As a result, at times it may be necessary for us to make changes to this Notice to reflect changes in the law, our data handling practices, or the features of our services, websites, and apps. We reserve the right, in our sole discretion, to update or modify this Notice at any time. Modifications to this Notice will be posted on the Site and the new Effective Date will be displayed at the top of this Notice. In certain circumstances, Versa may, but need not, provide you with additional notice of such modifications, such as via e-mail. Modifications will be effective 30 days following the Effective Date, or such other date as communicated in any other notice to you. Where required by applicable law, we will apply changes only with your consent.

Please review this Notice periodically, and especially before you provide any Personal Information. This Notice was updated on the date indicated above. Your continued participation in our programs, services, and events following the effectiveness of any modifications to this Notice constitutes your acceptance of those modifications. If any modification to this Notice is not acceptable to you, you should cease accessing, browsing, and otherwise utilizing Versa’s website, as well as its services and related content.

10. HOW TO CONTACT US

If you have any questions regarding this Notice or the use of your Personal Information under this Notice, you can contact us at:

  • Mail: VCM Fund Advisors, LLC, 1801 Market Street, Suite 2525, Philadelphia PA 19103

  • Telephone: (215) 609-3400

  • Facsimile: (215) 609-3499

  • Email: info@versa.com