CCPA Privacy Policy

Last Revised: May 20, 2023

THE CCPA AND YOUR PERSONAL DATA RIGHTS

The California Consumer Privacy Act (CCPA) grants California residents increased control over their personal information.

This CCPA privacy notice is for such California residents and supplements the Website Privacy Policy provided by Infra America Capital, LC and its affiliates (collectively, “IAC,” “we,” or “us”). It provides the details you need regarding rights that you have under the CCPA, and how to exercise those rights. It also provides you with the contact information you need to take action regarding the privacy of your information.

Defining Personal Information

Various laws and regulations (including the CCPA) use different terms and definitions for information about individuals that is personal and should be protected. Some laws and regulations consider only very limited types of information to be protected and private. Others include much broader categories. The CCPA sets out obligations and rights in relation to “personal information”, meaning information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

Types of Collected Information

Personal Information

IAC collects some personal information about you. This section describes the categories of personal information that are collected, as well as the categories of sources for obtaining that personal information, and the purpose for collecting it.

Personal Information Categories

The personal information we collect from you and have collected from you over the past 12 months consists following categories:

Contact Information

Information from Cookies

Job applicant information

Other personal information you voluntarily provide to us.

Sources of Personal Information

We obtain, and in the past 12 months have obtained, personal information directly from you, our affiliates, portfolio companies and other service providers, including by example, underwriters, brokers, trustees, legal advisors and accountants.

If you apply for employment at IAC, we also obtain and have obtained in the past 12 months information from third parties that you authorize us to contact or receive information from.

Purpose for Collecting Your Personal Information

We collect your personal information to:

You may elect not to provide us with information, but doing so may prevent us from providing you with services you may request. If you are currently receiving information or marketing communications from us, however, you may opt-out of receiving further communications at any time using one of the contact methods listed below.

Sharing Your Personal Information

We do not sell personal information about you to third parties and have not done so in the past 12 months.

We share and have shared in the past 12 months the categories of personal information outlined in the “Types of Collected Personal Information” section above:

Your Rights

The CCPA provides you with certain rights in regard to what we do with your personal information. This section details those rights, how to exercise them, and what IAC will do in response.

Disclosure

You have the right to request that we disclose to you, free of charge, the categories and specifics of the personal information we collect about you. We require a verifiable request from you to ensure that it is, in fact, you or someone authorized to act on your behalf who is requesting such a disclosure. Once we verify the request, we will provide that information to you. We may request specific information from you (such as a copy of your government issued ID) to help us confirm your identity and process your request. An authorized agent may make a request on your behalf by providing written permission signed by you.

Your request for disclosure can apply to any such personal information mentioned in the previous paragraph for as much as twelve months preceding your request. Be advised that we are not required to disclose such information about the personal information we collect about you more than twice in a twelve-month period.

Following our verification of your request, we will disclose to you, unless IAC is permitted to deny your request or is otherwise restricted by law or regulation:

Deletion of Personal Information

Where provided by law, you have the right to request that we delete the personal information we have collected from you. Following our verification of your request, we will comply with your request and delete any or all of your personal information in our possession that we collected from you, unless IAC is otherwise legally permitted to retain or is otherwise restricted by law or regulation.

Non-Discrimination for Exercising Your Rights

We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights set forth in this privacy notice.

Contacting Us to Exercise Your Rights

You may contact us in order to exercise any of your rights set forth in this privacy notice by calling this toll-free number +1-212-683-0400 or by contacting the IAC compliance team at compliance@infra-america.com.