Effective Date: June 05, 2023CCPA Notice
If you are an investor in an Insight Fund, then our investor privacy notice is applicable to you and the information we may collect in the course of providing financial services to you.
Note that when we say “Personal Information” in this Notice, we mean 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 does not include information that is aggregated or information that cannot be reasonably linked to you.
How We Collect, Use, and Disclose Personal Information
When you use our website, participate in certain Insight-sponsored programs, such as the Insight Partners Talent Network, or otherwise interact with us, we may collect certain Personal Information about you.
We do not sell or share any of your Personal Information.
Categories of Personal Information We May Have Collected About You
- Identifiers, which may include name, address, phone number, and e-mail address;
- Characteristics of protected classifications under California or federal law, such as race, ancestry, national origin, religion, age, mental and physical disability, sex, sexual orientation, gender identity, medical condition, genetic information, marital status, or military status;
- Internet activity information, which may include cookies, web server logs, web beacons, and other website tracking information or user activity;
- Audio, electronic, visual, thermal, olfactory, or similar information;
- Professional or employment-related information, which may include employment history, occupation, title, and employer information, as well as test or assessment results from your participation in the HireSelect program if you choose to provide it;
- Education information not considered publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act; and
- Inferences that can create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
Some of the information we collect about you, such as racial or ethnicity information, may be considered “sensitive personal information” under CCPA.
The business purposes for which we may have collected your Personal Information include:
- Communicating with you;
- Responding to your requests;
- Marketing to you;
- Organizing and conducting surveys or assessments sponsored by us on behalf of our portfolio companies;
- Improving or enhancing our services;
- Enhancing the functionality of our website;
- Training our employees, agents, associates, and partners;
- Promoting systems and data security;
- Providing a platform for our portfolio companies to identify qualified employment candidates;
- Monitoring compliance with applicable non-discrimination laws; and
- Performing other business purposes.
Parties to which your information may have been disclosed include:
- Third parties and service providers that perform services on our behalf;
- Insight portfolio companies, when you have directed us to disclose information to them, such as to consider you or your company for employment, partnership, or investment opportunities; or
- Law enforcement or other third parties in connection with legal requests or as required by law.
We have disclosed personal information to such third parties consistent with the business purpose(s) for which the information was collected, as described above.
Note that we will not disclose – and have not disclosed – with Insight portfolio companies any sensitive personal information, though we may disclose anonymized and aggregated data derived from such information.
Sources of Personal Information
The categories of sources from which we collect or receive Personal Information include you, your device(s), Insight portfolio companies or affiliates, third parties or services providers that provide service to you or perform services for us on our behalf, and publicly available sources.
How You Can Exercise Your Rights Provided Under the CCPA
Under the CCPA, you have the following rights if you are a resident of California:
- Right to Know: You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
- Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you;
- Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you;
- Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.
To exercise any of these rights, please contact us at email@example.com or (212) 230-9200.
Please note that to protect the integrity of our services and to protect your privacy interests, we will need to verify your identity before processing your request. We may need additional information to verify your identity and that your state of residence is California, if you choose to provide it. This could include: a driver’s license, permit, utility bill, subscription stub, mail, school ID card, or school record.
Under the CCPA, you may exercise these rights yourself or you may designate an authorized to make these requests on your behalf. If you choose to have an authorized agent act on your behalf, we may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
We do not sell your personal information to third parties, nor do we knowingly collect, sell or share the personal information of individuals under the age of 16.
Certain Exceptions Under the CCPA
As alluded to above, certain types of Personal Information are exempt from certain requirements of the CCPA. This includes:
- Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (and implementing regulations), or pursuant to the California Financial Information Privacy Act;
- Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate governed by the privacy, security, and breach notification rules issued pursuant to the Health Insurance Portability and Accountability Act of 1996, as amended;
- Personal information collected from a job applicant, employee, owner, director, staff member, officer, or contractor when the information is used in the context of the person’s role as a job applicant, employee, owner, director, staff member, officer, or contractor; and
- Personal information about an employee, owner, director, officer, or contractor of another business that is collected in connection with providing or receiving a product or service to or from the other business.
Covered business have limited obligations, or in some cases no obligations, under the CCPA with regard to these types of personal information.
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