This Online Privacy Policy constitutes a legally binding agreement between Riverwood and you, the user of this Website. By entering and using this Website, you acknowledge your acceptance of, and agree to be bound by, the Online Privacy Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Online Privacy Policy, please do not access or use this Website.
Visitors that are residents of California should also refer to our California Website Privacy Policy supplement.
What Information We Collect
This Online Privacy Policy applies to information collected from, or which may be submitted to, the Website.
At the present time, we do not collect any personally identifiable information about visitors to the publicly available areas of our Website, including any visitors’ names, addresses, phone numbers, or email addresses, unless a user submits such information to us via our “Contact” page. At times, visitors to our Website may choose to email individuals at Riverwood using links available on our Website; in such instances, a visitor’s email address may be collected as part of the process of sending the email to us in order to enable us to reply to those emails. In addition, we may receive information from you that you submit to us through the investor reporting portals and data rooms. If you are using our investor reporting portal or data room, you will receive our Privacy Notice applicable to investors which contains additional information on the personally identifiable connection collected in that context. We do not use any “cookies” technology on our Website.
How We Use Information We May Collect
To the extent that you provide us with any personally identifiable information through or in connection with this Website, we may use such information for Riverwood’s business purposes. We do not share or disclose any personally identifiable information collected from the publicly available areas of our Website with any parties outside of Riverwood, but we reserve the right to disclose any such information we do collect to the extent required by law, regulation, or legal or judicial process, including pursuant to a request from a regulatory agency with competent jurisdiction over Riverwood, or to service providers. In the event that a visitor submits its email address or any other personally identifiable information to us via our Website while requesting information or sending any email to someone at Riverwood, other than as described above or in the Privacy Notice, we will not use such information for any other purpose, and will not disclose such information to any outside party.
Access to Portfolio Company and Other Third Party Websites
Our Website contains links to websites controlled and maintained by third parties. We provide these links solely as a convenience for you. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites are used. This Online Privacy Policy does not govern the use of information collected on such third party websites.
Capacity
You represent to Riverwood that you have the authority to visit this website according to the Terms of Use. This Website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this Website who are under the age of 18 or knowingly collect personally identifiable information from anyone under the age of 18 without parental consent. If we learn we have collected or received personally identifiable information from an individual under the age of 18, we will delete that information.
Notification of Changes
We reserve the right to amend this Online Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Online Privacy Policy. Accordingly, users are strongly encouraged to review our Online Privacy Policy regularly. If we decide to change our Online Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Online Privacy Policy under which the information was collected. Your continued access or use of this Website following the posting of changes to this Online Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Online Privacy Policy, please stop accessing this Website. Please check this page frequently and review any changes to this Online Privacy Policy carefully so you are aware of any changes, as they are binding on you.
Contact Us
If you have any questions or concerns about this Privacy Policy, please contact the Chief Compliance Officer of Riverwood at cco@rwcm.com.
CALIFORNIA WEBSITE PRIVACY POLICY
Date: January 1, 2020
This California Website Privacy Policy supplements the Online Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Online Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
What Does This Privacy Policy Apply To?
This Website Privacy Policy applies solely to your interactions with us through the Riverwood website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.
What Information Do We Collect About You?
We collect limited types of personal information through our Website. The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
- Identifiers, such as name, contact details and address (including physical address, email address;
- Other customer records, such as telephone number and personal information provided in connection with obtaining account access;
- Commercial information, such as account data;
- Professional or employment-related information.
How Do We Obtain Your Personal Information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Information from your communications with us in connection with this Website, including any update notices provided by you.
- Information captured on our Website, including registration information and information provided through online forms.
How Do We Use Your Personal Information?
We will use your personal information for one or more of the following business purposes:
- To perform services for you.
- To improve our Website and the products and services that we offer and notify you about changes to our products and services.
- To communicate with you, including responding to requests for information submitted by you through our Website.
- To keep a record of your relationship with us.
- Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To audit and verify the quality and effectiveness of our services and compliance.
- To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.
Who Do We Share Your Personal Information With?
We do not sell any of the personal information we collect about you to third parties. We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, tax advisors, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries. Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this Website with affiliates and service providers as set forth above in “What information do we collect about you?” We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.
How Do We Keep Your Personal Information Secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your Rights Under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons. Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom we share the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
Contact Us
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below. Call us using the following toll-free number: 855-530-0663. Email us at the following email address: cco@rwcm.com. We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact the Chief Compliance Officer of Riverwood at the email address above with any questions about this California Website Privacy Policy.