Online Privacy Policy

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This Online Privacy Policy (“Privacy Policy”) describes how SteelBow Partners gathers and uses information for visitors of this website (“Website”). 

Your visit to the Website is subject to this Privacy Policy. By visiting this website, you agree to this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Website. Individuals who are residents of California should also refer to the California Residents section of this Privacy Policy for additional information applicable to them.

Terms such as “SteelBow,” “SteelBow Partners,” “we,” “our,” and “us” refer to SteelBow Partners, LLC and its related subsidiaries and affiliates.

THE INFORMATION WE COLLECT

When you visit and browse this Website, we may collect three different types of information about you: 

(i) information you provide, 

(ii) information we collect through technology, and 

(iii) information we collect from third parties.

Information you provide

You may reach out to us using the contact options available on the Website, including email. If you choose to do so, we will collect your name, company affiliation, email address, and any additional information you voluntarily provide. Based on our interactions, we may also collect information such as your mailing address, job title, telephone number, and a record of our communications. Please do not submit personal information you prefer not to disclose.

Information we collect through technology

When you visit the Website, we may collect certain technical information by automated means (e.g., cookies, web server logs, JavaScript, etc.). This information may include details about the browser, device and Internet connection that you use when you browse our Website, the operating system you use, your IP address, referring URLs, geographical location of the user, and dates and times of website visits. We may also use these items and similar technology in emails we send to collect certain information, such as whether you opened or clicked on links in our email.

As well as the technical information above, we may collect information about your visits to the Website, including the full web addresses that you access, your path of clicks, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We use third-party web analytics services on our Website, such as those of Google Analytics. These service providers help us analyze how visitors use the Website. The information obtained for this purpose (including your IP address and other information collected by automated means) may be disclosed to or collected directly by these service providers.  You may learn more about the practices of these analytics providers by visiting the privacy policies on their webpages. 

The providers of third-party plugins and widgets on the Website, such as embedded videos, may also use automated means to collect information regarding your use of the Website and your interactions with the plugins and widgets. This information is subject to the privacy policies or notices of the providers of the plugins and widgets.

Our Website contains links to websites controlled and maintained by our current or former portfolio companies and other third parties, such as social media networks. We provide these links solely as a convenience for you. These features are recognizable by their third-party brand or logo and may collect your IP address and set a cookie to enable the feature to work properly. 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 is used.  This Online Privacy Policy does not govern the use of information collected on such third-party websites.

Information we collect from third parties

We may also collect information from third parties including your employer or funds or other third parties with whom you are associated, such as a resume received from a recruiting firm, background information received from a background check provider, information we view on social media, or information we receive for anti-money laundering purposes. We also collect information from business partners and vendors to support our provision of investment services. We do not provide individual notice upon receipt of such personal information, and our receipt and use may be governed by these third parties.

HOW WE USE YOUR INFORMATION

We may aggregate the information we collect for any purpose, and may also use, disclose, or otherwise handle your information for one or more of the following business purposes:

• To verify your identity;
• For the purposes for which you provided the information to us or a service provider;
• To communicate with you, including responding to requests for information submitted by you through our Website and keeping you informed about our investment activities;
• To provide and improve our investment services, including sourcing, evaluating, and managing potential and existing investments;
• Developing new investment opportunities;
• To improve the content and features of the Website;
• To keep a record of your relationship with us;
• For ongoing operations, administrative, accounting, reporting, account maintenance and other processes;
• To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity;
• To administer and troubleshoot the Website;
• To generally comply with U.S., state, local and non-U.S. laws, rules, regulations, subpoena and court orders;
• For recruiting purposes; and 
• To enforce the legal terms that govern your use of the Website.

HOW WE SHARE YOUR INFORMATION

We do not sell information that we collect about you to unaffiliated third parties. We do not disclose the information we obtain about you through this Website except as described in this Privacy Policy. Depending on the nature of your relationship with us, we may disclose your information in the following circumstances:

• With your consent;
• To our affiliates, including for marketing and research purposes;
• To providers of website analytics services and third-party providers of plugins and widgets;
• To other services providers, including but not limited to, auditors, accountants, administrators, financing sources, banks, law firms, consultants, insurance brokers, and placement agents;
• As permitted or required by applicable law or regulation, including to  governmental agencies, self-regulatory organizations, or pursuant to legal process; and
• To other 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 or assets.

CHILDREN’S PRIVACY

This Website is only intended for individuals who are 16 years of age or older. We do not knowingly encourage or solicit visitors to this website who are under the age of 16 or knowingly collect personal information from anyone under the age of 16 without parental consent. If a minor under 16 has provided personally identifiable information to us through the Website, a parent or guardian may inform us of that fact using the contact information below, and we will use commercially reasonable efforts to delete it from our database, subject to applicable law and this Privacy Policy.

SECURITY

We consider the protection of sensitive personal information to be a sound business practice, and to that end, we employ appropriate safeguards in an effort to protect sensitive personal information in our possession or under our control to the extent possible from unauthorized access or improper use.

Unfortunately, the transmission of information and data via the Internet is not completely secure. We cannot guarantee the security of any information or data transmitted to or through this Website. Any transmission of information or data by you to or through this Website is at your sole risk.

DO NOT TRACK

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.

Third parties, such as our analytics, plugins, and widgets providers, may collect data that relates to you on the Website, across time, and over other websites. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. A third party’s use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

RETENTION

We will retain your information pursuant to our record retention policy for as long as necessary to fulfill the purposes set out in this Privacy Policy or for as long as necessary pursuant to applicable law or regulation, or as needed to protect our legal rights.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION 

The laws of some countries require companies to tell you about the legal grounds they rely on to use or disclose your personal information. To the extent those laws apply, our legal grounds for processing your personal information are as follows:

• Legitimate Interests. We process personal information to accomplish our legitimate interests in pursuing commercial activities, including, for example: (i) providing our investment advisory services, (ii) communicating with you, including responding to your inquiries, (iii) addressing information security, (iv) providing and maintaining the Website, (v) analyzing and improving our business, and (vi) managing legal and regulatory concerns.  Where we do process personal information, we seek to do so in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals.
• Legal & Compliance. We need to use and disclose personal information in certain ways to comply with our legal and regulatory obligations.
• Consent. Where we collect personal information from a third party that has obtained your consent, we may process your personal information on the basis of that consent.
• Comply with our Contractual Commitments. We also process personal information in order to meet our contractual obligations to our clients or in anticipation of entering into contracts with them.

CONTACT US

In the event that you have any questions or concerns about this Privacy Policy, or if you object to our uses of your personal information, please contact us at privacy@steelbowpartners.com.

CALIFORNIA RESIDENTS

This California Residents Privacy Policy (this “California Privacy Policy”) supplements this SteelBow Partners Online Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended from time to time, including by the California Privacy Rights Act of 2020, the “CCPA”) to natural persons who are residents of California and provides information regarding how California residents can exercise their rights under the CCPA. This California Privacy Policy is only relevant to you if you are a resident of the state 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 California Privacy Policy is otherwise set forth in the Privacy Policy above.

What information do we collect about you?

We may collect the following categories of personal information about you. The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we may collect include the following:

• Identifiers:  Identifiers such as a real name, alias, mailing address, unique personal identifier (such as cookies), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, tax identification number, and other similar identifiers;
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit/debit card number, and other financial information;
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status;
• Commercial information: such as account data, financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies;
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
• Employment and Educational Information: professional or employment-related information and educational history;
• Other customer records: such as telephone number and personal information provided in connection with obtaining account access;
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes; and
• Sensitive personal information.

We do not knowingly collect or solicit personal information from anyone under the age of 16.

Sensitive personal information

We may collect information that is considered “sensitive” under some data protection laws including the CCPA. For example, we or our vendors on our behalf, store account log-in information from users of our investor portal. We or others on our behalf may also receive government identifiers or similar information from individuals associated with investments we manage for anti-money laundering or other fund administrative purposes. When we or our vendors collect sensitive Personal Information, we use such information only for lawful purposes in compliance with applicable data protection laws, such as to perform the services or provide the goods requested by you and to resist malicious, deceptive, fraudulent or illegal actions. Where required by applicable law, we will obtain your consent prior to processing such information.

Sources of personal information

We collect the personal information categories described above from the sources described in THE INFORMATION WE COLLECT.

With whom do we share personal information

We may share each of the categories of personal information collected in connection with this Website with affiliates and service providers and as otherwise set forth above in HOW WE SHARE YOUR INFORMATION.

Your rights under the CCPA

If you are a natural person who is resident of the state of California, you may have the following rights in relation to personal information that we collect about you. To exercise these rights, please contact us at privacy@steelbowpartners.com.  We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

• Right to Know: You have the right to request additional information about what personal information we have collected and shared about you and our purposes for doing so. You may also have the right to request disclosure of the specific pieces of information that we collect about you.
• Right to Delete: You have the right to request that we delete any of your personal information that we retain, subject to applicable law or regulation.
• Right to Correct: You have the right to request that we correct inaccurate personal information about you that we retain, subject to applicable law or regulation.
• No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

If you make a request related to personal information about you, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, or, in some instances, provide a signed declaration that you are the consumer whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request to exercise one of the aforementioned rights through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

We will process your request within the time provided by applicable law.

Sale or sharing personal information

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for purposes of cross-context behavioral advertising. Pursuant to the definition of “sell” and “share” under the CCPA and applicable regulations, we do not engage in such activity and have not engaged in such activity in the last 12 months, including for minors under 16. Please note, we do share certain personal information with our service providers including for purposes of site analytics, as well as with certain other entities as set forth in HOW WE SHARE YOUR INFORMATION.

Your California Privacy Rights: California Shine the Light Disclosure 

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.

CHANGES TO THIS ONLINE PRIVACY POLICY

This Online Privacy Policy was last updated on January 13, 2026. We reserve the right to modify, amend, supplement, replace, or remove any portion of this Online Privacy Policy at any time in our sole discretion. Any changes we may make to this Online Privacy Policy in the future will be posted on the Website, and such changes will become effective upon posting unless otherwise stated.