Terms of Service

1. Introduction

Your privacy is important to us. This Privacy Policy describes how Melrose Ascension Capital, LLC and its affiliates and subsidiaries (collectively, “MAC,” “we,” “us,” or “our”) collect, use, share, and otherwise process your Personal Information (as defined below) in connection with the following (collectively, the “Services”):

• Our website at melrose-capital.com and any other websites operated by MAC that link to this Privacy Policy (collectively, the “Website”), including any mobile or digital services provided in connection therewith;
• Our direct marketing communications;
• Our events, property-related activities, and other offline activities where we have posted or referenced this Privacy Policy.

Your decision to use our Services and provide your Personal Information is voluntary. We indicate on our online and other forms what types of Personal Information are requested. You may choose not to submit requested Personal Information, but doing so may limit the services we are able to provide to you.

Please do not provide Personal Information that you do not want us to have.

We recognize that information privacy is an ongoing responsibility, and we will from time to time update this Privacy Policy as we undertake new practices or adopt new privacy policies. You are encouraged to review this page periodically so that you are aware of any changes. By using our Services, you agree to be bound by the then-current version of this Privacy Policy.

2. Definitions

“Personal Information” means any data that relates to a living individual who can be identified from that data, or from that data taken together with other information in the possession of, or likely to come into the possession of, MAC (or its representatives or service providers). Personal Information may include, but is not limited to, first name, last name, email address, mailing address, phone number, company or organization name, and Usage Data. For California residents, “Personal Information” includes the definition under the California Consumer Privacy Act (“CCPA”).

“Usage Data” means information about how the Services are accessed and used. Usage Data may include, but is not limited to, your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

“Website” means MAC websites that link to this Privacy Policy unless such websites have their own posted privacy policies.

3. Cookie Notice

Our Website uses cookies, which are small data files transferred from a website and placed on the hard drive or browser of your computer, tablet, smartphone, or other device when you visit a website. Cookies may include strictly necessary, performance, functional, and personalization cookies, as well as similar information-gathering technologies such as pixel tags or web beacons. For more information about these tools and your choices, please refer to Section 6 (Your Rights & Choices) below and https://www.allaboutcookies.org/.

4. How We Collect & Use Personal Information You Provide to Us

MAC protects the identity of visitors to the Services by limiting the collection of Personal Information. Personal Information provided by you will not be posted or published by us and will be shared with third parties only as described herein. When you visit our Website or otherwise interact with us, we or our third-party service providers may collect Personal Information that you voluntarily choose to share with us, including:

• Contact information, such as your first and last name, email address, mailing address, and phone number.
• Professional information, such as your company or organization name, job title, and professional role.
• Communications, such as questions, inquiries, or correspondence that you send to us through our Website or other channels.
• Investment-related information, such as information you provide in connection with investment partnership inquiries, co-GP platform inquiries, or capital markets discussions.
• Marketing data, such as your preferences for receiving communications about our activities, projects, events, and publications.
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

We do not sell or share (i.e., disclose to third parties for the purpose of cross-contextual advertising) your Personal Information. We only disclose Personal Information to our third-party service providers who help facilitate the delivery of our Services.

Communications From Us

If you choose to provide us with Personal Information, you may receive the following types of communications from us:

• Communications related to Website maintenance or service-related activities;
• Updates about our development projects, investment activities, and firm news;
• Invitations to events, property tours, and other MAC-hosted activities;
• Information about investment opportunities and partnership inquiries; and
• Other promotions and offers we believe may be of interest to you.

Purposes for Processing Personal Information

We may use your Personal Information for one or more of the following business or commercial purposes:

• To perform services for you and to respond to your inquiries.
• To provide, support, personalize, develop, and improve our Website and the products and services we offer.
• To communicate with you, including responding to requests submitted through our Website.
• To provide advertising and marketing services.
• To maintain a record of our relationship with you.
• For ongoing operations, administrative, accounting, reporting, and compliance processes.
• To maintain the safety, security, and integrity of our Website, databases, technology assets, and business, including to detect and protect against malicious, deceptive, fraudulent, or illegal activity.
• To comply with applicable federal, state, and local laws, rules, and regulations, including responding to law enforcement requests and as required by applicable law, court order, or government regulation.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information held by us is among the assets transferred.

5. Information Collected Automatically & Other Information

Like other commercial websites, MAC and our authorized third-party service providers may use cookies and similar technologies throughout our Website to collect certain information automatically and store it in log files. This information may include (but is not limited to) Usage Data and other information about your use of our Website, including a history of the pages you view.

We may also receive information about your use of our Website from other sources, including third-party websites. This information may include data about your activities across unrelated websites and applications, demographic data, and information from social media providers. We may combine this information with data we have already collected through our Website.

Links to Third-Party Websites

Our Website may contain links to other websites or applications developed and maintained by third parties. These third-party services may use automated means to collect information about you and your use of their features. MAC is not responsible for the privacy practices or content of these third-party services. We encourage all users to follow safe internet practices and to review the privacy policies of any third-party services before providing Personal Information.

Purposes for Processing Automatically Collected Information

We may process information collected automatically for any purpose, except where it constitutes Personal Information or is otherwise prohibited by applicable law. If we combine automatically collected information with your Personal Information, we treat the combined information as Personal Information. Specifically, we may use this information to design and improve our Website, for statistical and market research purposes, and for analytics through tools such as Google Analytics.

6. Your Rights & Choices

Marketing Opt-Out

You can unsubscribe from our marketing communications by clicking the “unsubscribe” link located at the bottom of our emails or by contacting us as indicated in Section 11 below.

Managing Cookies

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Website. For more information, please visit https://www.allaboutcookies.org/.

7. “Do Not Track” Signals

When you visit a website, your browser may automatically share certain information with that website, such as your IP address and other standard device information. If you activate the “Do Not Track” setting in your browser, your browser will ask the websites you visit not to track you. At this time, our Website does not respond to “Do Not Track” signals. You can learn more about “Do Not Track” at https://allaboutdnt.com/.

8. Data Security

MAC uses reasonable measures, including administrative, technical, and physical safeguards, to protect your Personal Information from loss, theft, and misuse, as well as against unauthorized access, alteration, disclosure, or destruction. However, no internet-based service or electronic data transmission can be guaranteed to be completely secure. We encourage you to exercise caution when transmitting Personal Information over the internet.

9. Data Retention

We retain Personal Information for as long as we reasonably require it for legal or business purposes. When determining data retention periods, we take into consideration applicable laws, contractual obligations, and the expectations and requirements of our users. When we no longer need Personal Information, we securely delete or destroy it.

10. Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) provide you with certain rights regarding your Personal Information, including:

• Right to Know: You have the right to request that we disclose the categories and specific pieces of Personal Information we have collected about you.
• Right to Delete: You have the right to request deletion of your Personal Information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate Personal Information.
• Right to Opt Out of Sale/Sharing: You have the right to opt out of the sale or sharing of your Personal Information. As stated above, MAC does not sell or share your Personal Information.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA/CPRA rights.

To exercise any of these rights, please contact us as described in Section 11 below. We will verify your identity before fulfilling your request.

11. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how your Personal Information is being handled, please contact us at:

Melrose Ascension Capital
Chicago, Illinois
nmelrose@melrose-capital.com

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with a revised “Last Updated” date. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.