FTV Management Company, L.P.
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Privacy Policy

Last Updated: April 2025

Thank you for your interest in FTV Management Company, L.P. (“FTV,” “we,” “us,” or “our”). We provide this Privacy Policy (the “Policy”) to describe our privacy practices, including the personal information we collect, how we use it, and when we disclose it. Except as described below, this Policy applies to all personal information we collect, including information collected from our websites and online services on which we display this Policy (the “Sites”), the information we collect to manage the funds comprising FTV Capital (the “Funds”), and information collected offline (collectively including the Sites and the Funds, the “Services”). This Privacy Policy does not apply to FTV employees or job applicants.

By accessing or using the Services or otherwise providing us with information, you acknowledge the applicability of this Policy. If you do not agree to this Policy, please do not access or use the Services or provide us with information.

1. Information We Collect

We collect information about you in different ways. You may provide information directly to us; we may collect it automatically when you use or otherwise access our Services; and we may also collect it from other parties. We need certain types of information to provide the Services. For example, we need certain information to manage our Funds. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain aspects of the Services.

a. Information You Provide to Us Directly

We may collect information that you provide to us directly. For example, you may provide us with information when you:

  • Use the Services, such as investing in our Funds;
  • Interact or otherwise communicate with us, including by email, investor questionnaires, applications or other forms, or in person such as at conferences or other events; or
  • Subscribe to our newsletters, insights, or updates.

The information you provide directly to us may concern you and others and may include, but is not limited to:

  • Name;
  • Email address;
  • Mailing address;
  • Job position or title;
  • Phone number;
  • Financial information;
  • Photographs;
  • Transaction information, including information about your transactions with us or others; and
  • Communications, such as when you make inquiries or otherwise communicate with us.

b. Information We Collect Automatically

Device/Usage Information. We and our third-party vendors, which include ad networks and analytics companies such as Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Sites. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); (i) version of our Sites you’re using; and (j) the type of device that you use. We may also track when and how frequently you access or use the Sites, including how you engage with or navigate our Sites. We use this information (including the information collected by our third-party vendors) for analytics (including to determine which portions of the Sites are used most frequently and what our users like/do not like), to evaluate the success of our advertising campaigns, and as otherwise described in this Policy.

Cookies and Other Electronic Technologies. We and our third-party vendors may use cookies, clear GIFs, JavaScript tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Services. These technologies, for example, may allow us to tailor the Services to your needs, save your password in password-protected areas, track the pages you visit, help us manage content, and compile statistics about usage of our Services. We or our third-party vendors also may use certain of these technologies in emails to our investors and users to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods. You may learn more by visiting our Cookie Policy. For more information, see https://www.allaboutcookies.org/.

Location Information. When you use the Sites, we may collect general location information (such as general location inferred from an IP address).

c. Information We Collect From Affiliates and Other Parties

We may collect information about you or others through our affiliates or through non-affiliated parties. This may include information in the public domain, such as publicly-available information in social media profiles. We may combine information that we collect from you through the Services with information that we obtain from such other parties and information derived from other products or Services we provide.

2. How We Use the Information We Collect

We use the information collected about you through the Services for business purposes, including:

  • To provide our Services;
  • To process transactions with you;
  • To conduct due diligence in connection with our Services;
  • To communicate with you, including to respond to your inquiries or register you for newsletters, insights, or events;
  • To manage our relationship with you and your business;
  • For marketing and promotional purposes;
  • For research and analytics purposes;
  • To verify your identity;
  • To administer and troubleshoot the Services; and
  • For other business and legal purposes, such as to comply with our legal obligations, enforce our terms of use, defend our legal rights, protect our operations, security and property, or that of our users, employees, or other parties; and as an incident to any sale, merger or similar transaction involving our company.

We may aggregate and/or de-identify information collected through the Services. We may use de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes and may also disclose such data to other parties such as business partners.

3. When We Disclose Information About You

We may disclose information about you in the following situations:

  • Affiliates. We may disclose information to our affiliates and our and their respective officers, directors, managers, partners, members, shareholders, employees, affiliates and agents.
  • Vendors. We may disclose data to vendors, contractors or agents who perform services on our behalf. They provide a variety of services to us, including data storage, analytics, billing, marketing, product content and features, customer service, data storage, security, fraud prevention, and legal services.
  • Business Transfers. We may disclose or transfer data to another company as part of an actual or contemplated merger, sale, or acquisition of us by that company.
  • Legal Obligations and Rights. We may disclose your data: (i) in connection with establishing, exercising or defending against legal claims; (ii) to comply with laws, lawful requests or legal process; (iii) to protect our rights or those of our employees; (iv) protect your safety or that of our employees or others; or (v) as otherwise permitted by applicable law.
  • Consent/At Your Direction. We may disclose your information to nonaffiliated third parties based on your consent to do so.

4. Cookie Policy

When you interact with our website, we automatically collect information about your device and browsing activity using cookies and similar technologies to enable the operation of our website, provide additional website functionality, collect analytics and market our Services. Please see our Cookie Policy for more details.

5. Your Choices

You have certain rights and choices with respect to your information such as:

  • Account Information: You can update certain of your information within your Investor Portal account.
  • Marketing Communications: You can unsubscribe from marketing emails by following the directions in those emails. Please note that if you unsubscribe from marketing emails, we may still send you administrative emails regarding the Services, including, for example, notices of updates to the Terms of Use or this Policy.
  • Cookies & Analytics: You can opt out of certain cookie-related and analytics processing by following the instructions in the Cookie Policy.

Your local law may provide you certain rights with respect to your information. Depending on your jurisdiction, you may request that we:

  • provide access to and/or a copy of certain information we hold about you;
  • prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
  • update information which is out of date or incorrect;
  • delete certain information that 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; and
  • revoke your consent for the processing of your information.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue 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. To exercise any of these rights, please contact us as described in the “Contact Us” or “Additional Regional Disclosures” sections below, as applicable.

Additional disclosures for residents of the European Economic Area, United Kingdom, and California are set forth below in Additional Regional Disclosures.

6. Links to Third-Party Sites and Services

The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information by third parties will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties before providing information to them.

7. Security and Data Retention

We have implemented procedures to safeguard and secure the information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. No security measures, however, are perfect. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or communications will not be collected, disclosed and/or used by others.

We keep your information for the time 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 your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. Children’s Privacy

Our services are not designed or meant for children. We do not knowingly collect personal information from children under 18. If we discover that an individual under 18 has provided us with personal information, we will delete that personal information to the extent required by the Children’s Online Privacy Protection Act.

9. Consent to Transfer

Our Services are global and your information may be stored and processed in the United States and other countries outside the United States that may have data protection laws that differ from the laws in your country. For example, our employees may access your information from the United States and data may be accessible to law enforcement and national security authorities under certain circumstances. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information in and to the United States and other applicable countries in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen.

10. Additional Regional Disclosures

a. Residents of the European Economic Area and United Kingdom

FTV is the “data controller” of the “personal data” (as defined under the General Data Protection Regulation (“GDPR”)) we handle under this Policy. In other words, FTV is responsible for deciding how to collect, use and disclose this personal data, subject to applicable law. The laws of the European Economic Area and the United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your personal data. To the extent those laws apply, our legal grounds are as follows:

  • Contractual Commitments: We may use, share, or disclose personal data to honor our contractual commitments to you. For example, we will process your personal data to comply with our agreements with you, and to honor our commitments in any contracts that we have with you. For example, we may process personal data in connection with Funds in which you have invested.
  • With Your Consent: Where required by law, and in some other cases, we use, share, or disclose personal data on the basis of your consent. You may withdraw any consent you previously provided to us regarding the processing of your personal data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
  • Legitimate Interests: In many cases, we use, share, or disclose personal data on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for the Services, preventing fraud, and managing legal issues.
  • Legal Compliance: We need to use, share, and disclose personal data in certain ways to comply with our legal obligations.

In addition to those rights described herein, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

b. Residents of California

The following information applies to California residents regarding “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). This information and the rights discussed below do not apply to information collected about FTV employees, former employees, candidates, or independent contractors. It also does not apply to personal information governed by the Gramm-Leach-Bliley Act. In this section, where we use a term in “quotes,” we refer to the meaning of that term in the CCPA.

i. Categories of personal information we collect, use, and disclose

Throughout this Policy, we discuss in detail the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we must also provide you with the “categories” of personal information and sensitive personal information we collect and disclose for “business or commercial purposes” (as those terms are defined by the CCPA).

As further described above in Section 1, we collect the following categories of personal information:

  • Identifiers, such as name and email address;
  • Internet or other network or device activity, such as browsing history on our Sites and device identifiers;
  • Professional and employment-related information, such as information about the company you work for;
  • Financial information, such as financial account information related to your investment in our Funds;
  • General location data, such as that derived from an IP address;
  • Commercial and transaction information;
  • Audio and visual information, such as audio, video, and chat conversations; and
  • Other information that identifies or can be reasonably associated with you, such as information you may include in communications with us.

We collect these categories of personal information for the purposes described above in Section 2. We disclose information as described above in Section 3. We collected these categories of information from the following sources: (1) directly from you; (2) through your use of the Services and other interactions with us; (3) affiliates; and (4) other parties, such as business partners.

Some of the information we collect may also be “sensitive personal information,” as that term is defined in the CCPA. You may voluntarily provide us with “sensitive personal information,” such as through communications with us.

ii. “Sale” and “sharing” of personal information

The CCPA sets forth certain obligations for businesses that “sell” or “share” personal information.

We may disclose your personal information to third parties for purposes of analytics. We provide information to analytics providers to better understand how consumers use the Services so we can improve the Services and create new products and services. We may also provide personal information to third-party advertising providers for targeted advertising purposes, so we can provide you with more relevant and tailored ads regarding our services. No mobile information will be shared with third parties for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. Under the CCPA, disclosing personal information to these third parties may be considered a “sale” of personal information or the “sharing” of personal information for purposes of “cross-context behavioral advertising.”

We do not knowingly “sell” or “share” the personal information of children under 16.

You can opt out of our “sales” or “sharing” of your personal information by following the instructions below.

iii. Your CCPA rights

If you are a California resident, the CCPA may permit you to request that we:

  • Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting, “selling,” or “sharing” your personal information; the categories of third parties to whom we disclose or “sell,” or with whom we “share,” personal information; and the categories of personal information we “sell” or “share” (much of which is provided above).
  • Provide access to and/or a copy of certain information we hold about you.
  • Delete certain information we have about you.
  • Correct inaccurate personal information that we maintain about you.

You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.

Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services. To exercise these rights, you will be required to verify your identity, and we may request additional information from you to verify your identity. To exercise your rights, please submit your request at info@ftvcapital.com.

You also have the right to opt out of “sales” and “sharing” of personal information. Please submit your request here: Do Not Sell or Share My Personal Information.

Please note that we also respond to and abide by opt-out preference signals sent through the Global Privacy Control. Any opt out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use the Global Privacy Control, see www.globalprivacycontrol.org.

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your “sensitive personal information” is used for certain purposes. Please note that we do not use or disclose “sensitive personal information” other than for purposes for which you cannot opt exercise the right to limit under the CCPA.

You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

iv. Retention of your personal information

Please see the section above on Security and Data Retention.

v. Do-Not-Track disclosure

We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions. Please note that Do Not Track is a different privacy mechanism than the Global Privacy Control browser choice referenced above.

11. Changes to this Policy

We may change or update this Policy from time to time, so we encourage you to review this Policy periodically. If we make any material changes to this Policy, we will notify you as required by law, such as by e-mail to the address you have provided. By continuing to access or otherwise use the Services, you agree to the terms of the then-current Policy.

12. Contact Us

If you have questions about this Policy, please contact us at info@ftvcapital.com or by mail at 601 California Street, Floor 19, San Francisco, CA 94108.