Legal and Privacy

Silver Lake Terms of Use

Last Updated: April 6, 2022

These Silver Lake Terms of Use (“Terms of Use”) apply to the Internet sites of Silver Lake Technology Management, L.L.C. and its affiliates (“Silver Lake” or “we”), including www.silverlake.com, all sites hosted within or associated with that domain, and any other affiliated sites that we operate on which these Terms of Use are posted (collectively, the “Site”). Please read these Terms of Use carefully before using the Site. These Terms of Use set forth the legally binding terms and conditions that govern your access to and use of the Site, including all materials, information, and content thereon (collectively, the “Content”). By visiting the Site, you accept, and agree to be bound by, these Terms of Use. We may update the Site or these Terms of Use at any time without notice. Any update to these Terms of Use will be effective upon posting the modified version of these Terms of Use on the Site. We encourage you to periodically consult these Terms of Use to learn about any modifications thereof and updates thereto. Your continued use of the Site after any such modifications or updates to these Terms of Use shall constitute your acceptance of these Terms of Use as modified or updated. If you do not agree to these Terms of Use for any reason, please discontinue your access and use of the Site.

If you have any questions or comments about these Terms of Use, you can write us at Website Inquiry c/o Legal and Compliance, Silver Lake, 2775 Sand Hill Road, Suite 100, Menlo Park, CA 94025.

Uses of Our Site and Content

We have the right (but not the obligation) to monitor the Site for any unauthorized or objectionable conduct and to take all appropriate actions in response, without notice to you. We have listed below the permitted and prohibited uses of our Site and the Content.

You may copy, download, and print individual pages of our Site for your own personal use and not for any commercial use or purpose. You may not remove any copyright, trademark, or other proprietary notices or other legends from any such pages. You may not alter or modify the Content in your copies.  In no event may you (i) extract, copy, or download a large portion of the Content, such as by a bot, webcrawler, scraper, spider or other device that “harvests” portions of the Site, (ii) make more than a few copies of a given page of the Site or copy a substantial portion of the Site or any Content, or (iii) engage in any commercial exploitation of any of our Content, or post it elsewhere on the Internet.

You may not (and may not encourage others to) attempt to violate the security of this Site or use or gain access to the identities, information, or computers of others, through this Site or use the Site to violate any law or regulation or the intellectual property, privacy, or publicity, or contractual rights of others.

Trademarks and Other Intellectual Property

SILVER LAKE®, SILVER LAKE PARTNERS®, SLP®, SILVER LAKE ALPINE™, SLA™, SILVER LAKE LONG TERM CAPITAL™, LTC™, SILVER LAKE SUMERU®, SUMERU®, SLS™, SILVER LAKE KRAFTWERK®, SLK™, SILVER LAKE WATERMAN™, SLW™, and certain other marks or logos displayed on the Site are trademarks and service marks of and owned by Silver Lake or other parties, who may or may not be affiliated with Silver Lake. You may not use any of those or any other Silver Lake trademarks, trade names, or service marks in any manner that creates the impression that such names and marks belong to or are associated with you or your affiliates or are used with Silver Lake’s consent.

All trademarks or service marks on the Site that are not owned by Silver Lake are the property of their respective owners. You may not use any such trademarks or service marks without the permission of their respective owners. All Content included on the Site is owned by Silver Lake or other parties, and is protected by copyright and other intellectual property law.

No Offer or Advice

The Content included on the Site is for informational purposes only and does not constitute an offer to sell or buy any securities, financial instruments, investments, or other services of Silver Lake or any entity, and may not be used or relied upon in connection with any offer or sale of securities, financial instruments, investments, or other services. An offer or solicitation will be made only through a final private placement memorandum, subscription agreement, and other related documents with respect to a particular investment opportunity and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor.

Silver Lake is not utilizing the Site to provide investment or other advice, and nothing on the Site is to be deemed a recommendation that you buy, sell, hold, or make any other security or investment decision.  The Site and its Content should not be relied upon for the purpose of making or communicating investment or other decisions nor construed as investment, legal, accounting, tax, or other professional advice. To obtain such advice, you should consult with your own professional advisor.  Any transactions listed on the Site are included as representative transactions and are not necessarily reflective of overall performance. 

Not Advertising or Marketing Material

The Content on the Site is for informational purposes only and is not, and should not be considered as, an offer to provide investment advisory services with regard to securities to any person or entity.

Forward Looking Statements

The Content on the Site may contain forward­-looking statements that are based on beliefs, assumptions, current expectations, estimates, and projections about the financial industry, the economy, Silver Lake itself or its investments. These statements are not guarantees of future performance and involve certain risks, uncertainties, and assumptions that are difficult to predict with regard to timing, extent, likelihood, and degree of occurrence. Therefore, actual results and outcomes may materially differ from what may be expressed or forecasted in such forward­-looking statements. Furthermore, Silver Lake undertakes no obligation to update, amend, or clarify forward­-looking statements, whether as a result of new information, future events, or otherwise.  

Past Performance is Not Indicative of Future Results

Any performance-related Content on the Site is exclusively an indication of past performance. Silver Lake makes no representation that any investment or transaction will result in profits or losses similar to those achieved in the past, or that significant losses will be avoided. Certain companies represent past and present investments made by multiple Silver Lake Funds which may have different strategies, including with respect to degree of governance or involvement by Silver Lake. Some information herein may reflect our strategic principles and historic performance from which we have developed general theses, but there is no guarantee that historical trends will continue into the future or that our strategy and principles will ultimately prove to be correct.

Links to Other Websites

The Site may contain links to, or may be linked from, other websites that are not maintained by us. Silver Lake does not endorse, have any responsibility for or control over, or make any representations about, any other websites, including their products and services, content, communications, and website use policies. If you access or follow links to websites not affiliated or controlled by us, you do so at your own risk. We encourage you to review the terms and conditions, privacy policies, and other user agreements of all such websites that you visit as such terms and conditions, policies, and agreements will govern your access and use of those websites. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information. Silver Lake expressly disclaims any responsibility for your access to or use of such other websites.

Disclaimers

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SITE AND ALL CONTENT AVAILABLE ON OR THROUGH THE SITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. You expressly understand that Silver Lake does not make and hereby disclaims all express and implied warranties, representations, and endorsements , including but not limited to, implied warranties of merchantability, fitness for a particular purpose, and warranties of title and non-infringement, as to the operation of the Site or the CONTENT. SILVER LAKE DOES NOT WARRANT THAT SUCH CONTENT IS ACCURATE, RELIABLE, OR CORRECT, THAT THIS SITE WILL BE AVAILABLE AT ANY PARTICULAR TIME OR LOCATION, OR THAT THE SITE IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.  YOUR ACCESS TO AND USE OF THE SITE AND ITS CONTENTS IS AT YOUR SOLE RISK.

You acknowledge and accept that: (1) the Site may not be available, may not function properly or may have or cause technological problems (including, without limitation, computer malfunction, failure of performance, delays, interruptions, defects, errors, worms, or viruses) from time to time; and (2) Silver Lake or its designee cannot, and does not, guarantee that the Site will be free of security problems (including, without limitation, unauthorized interception of data or communications).

All Content available on or through the Site is only as of the date indicated.  Although we make reasonable efforts to provide accurate information, Silver Lake undertakes no obligation to, and at times we may not promptly, update or correct the Site even if we are aware that it is inaccurate, outdated or otherwise inappropriate, whether as a result of new information, future events or otherwise.

Limitation of Liability

Silver Lake and its affiliates and all of their respective officers, directors, managers, partners, members, shareholders, employees, affiliates, representatives, licensors, and agents will not be liable hereunder for any direct or indirect damages or injury, including but not limited to special, incidental, punitive, or consequential damages (whether in an action in contract or tort or under statute), that result from the access to or use of (or the inability to access or use) the Site and its Content, or a website to which the Site links, including any damages or injury caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, line failure, or other computer malfunction, or from any action that you take or decision you make in reliance on any information contained in the Site. IN NO EVENT WILL SILVER LAKE’S AGGREGATE LIABILITY TO YOU, DIRECT OR OTHERWISE, EXCEED ONE HUNDRED UNITED STATES DOLLARS (USD $100). 

THE LAWS OF CERTAIN JURISDICTIONS MAY NOT ALLOW THE EXCLUSIONS AND LIMITATIONS OF DAMAGES IN THIS SECTION, IN WHICH CASE SILVER LAKE’S LIABILITY FOR DAMAGES IN CONNECTION WITH THESE TERMS OF USE IN SUCH JURISDICTIONS SHALL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY THE LAWS OF SUCH JURISDICTION.

Notwithstanding the foregoing, nothing contained in preceding paragraphs or elsewhere in these Terms of Use shall constitute a waiver by you of any of your legal rights under applicable U.S. federal securities laws or any other laws whose applicability is not permitted to be contractually waived.

Indemnification

You agree to indemnify and hold harmless Silver Lake and its affiliates and their respective officers, directors, managers, partners, members, shareholders, employees, affiliates, and agents from any and all liabilities, damages, losses, claims, expenses, and fees resulting from your access or use of the Site or your breach of these Terms of Use.

International Use

The Site is operated and controlled by Silver Lake in the United States. Access to the Site or distribution of the Content on the Site from countries or territories where such access or distribution is illegal is prohibited. Silver Lake makes no claims that the Site is appropriate or lawful for use or access outside the United States.  You are responsible for complying with all local laws, rules, and regulations.

Governing Law / Venue

You agree that your use of the Site and any disputes relating to the Site or these Terms of Use are governed in all respects by the laws of the State of New York without giving effect to any principles or rules of conflicts of laws to the extent such principles or rules are not mandatorily applicable by statute and would require or permit the application of the laws of other jurisdictions, as to all matters, including, but not limited to, matters of validity, construction, effect, performance, and remedies.

Silver Lake may bring an action against you in connection with any dispute, controversy, or claim arising out of these Terms of Use or your access or use of the Site (“Dispute”) in any jurisdiction.  Without limiting Silver Lake’s right to do so, you agree not to object to the exercise of personal jurisdiction by and to venue in the courts of the State of California and the United States District Court for the Northern District of California located in or near Menlo Park, County of San Mateo, California.  Silver Lake may elect to resolve any Dispute through binding arbitration and, if it so elects, you and we agree that such Dispute shall be resolved pursuant to the Commercial Arbitration Rules of the American Arbitration Association.  The seat of such arbitration shall be San Mateo, California, U.S.A. Any such arbitration will be conducted as an individual arbitration and you agree that no arbitration shall be brought by you or resolved on a class, mass, or representative basis.  You agree that any claim or cause of action arising out of or related to these Terms of Use or your access or use of the Site must be filed within one (1) year after such claim or cause of action arose regardless of any statute or law to the contrary.

Termination and Suspension

Silver Lake may terminate or suspend your access to the Site at any time, for any reason or no reason, with or without prior notice.

Additional Important Information

Please refer to Silver Lake’s Form ADV for additional information on relevant investment strategies.

Privacy Notices

You may view our privacy notices at the links below:

Website Privacy Policy

California Privacy Policy

California Job Applicant Privacy Notice

UK Recruitment Process Privacy Notice

Miscellaneous

If any provision of these Terms of Use is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms of Use, which shall remain in full force and effect. No waiver of any provision in these Terms of Use shall be a further or continuing waiver of such provision or any other provision in these Terms of Use. The section names in the Terms of Use are for convenience only and have no legal or contractual effect.  You may not assign these Terms of Use, or any of your rights or obligations hereunder, without the prior written consent of Silver Lake. We may assign, transfer or sublicense any or all of our rights or obligations under these Terms of Use at any time without your prior consent. Except as expressly provided elsewhere in the Site, these Terms of Use and any other terms and conditions expressly incorporated by reference into these Terms of Use by Silver Lake constitute the entire agreement between you and Silver Lake with respect to your use of the Site.

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Privacy Policy

Last Updated: January 31, 2024

California residents can find our California Privacy Notice, which supplements this Privacy Policy, at this link: https://www.silverlake.com/california-privacy-notice

General

This Privacy Policy applies to the Internet sites of Silver Lake Technology Management, L.L.C. (“Silver Lake”), including www.silverlake.com and affiliated sites, and our social media platforms and email account (collectively, the “Site”). We are committed to protecting the privacy of visitors to our Site. Silver Lake is the data controller in relation to personal information collected through the Site. 

This Privacy Policy describes the information we collect about you when you visit the Site or correspond with us via email, and how we use such information. This Privacy Policy does not address our privacy practices concerning any personal information we collect about our investors when investing in our funds; we address those practices in separate notices sent to our investors or potential investors.

Any update to this Privacy Policy will be effective upon posting a notice of the modified Privacy Policy on our Site. We encourage you to periodically consult this Privacy Policy to learn about any modifications and updates.

If you have any questions or comments about this Privacy Policy, you can contact us as described in the “How to Contact Us” section below.

Personal Information We Collect

Personal Information is information that personally identifies you, directly or indirectly, such as your name, postal address, email address, or credit card information (or other information that is associated by us with such information). 

The Site is directed toward and designed for use by persons aged 16 or older. We do not knowingly collect personal information from individuals under the age of 16.

Information You Provide

We may collect personal information that you choose to provide to us through the Site, including, but not limited to, your first and last name, physical address, email address, or telephone number, such as when you:

  • Fill out a form on the Site;
  • Sign up to a feature that we offer on the Site and you provide your personal information in connection with that feature;
  • Sign up to attend an event that we have organized;
  • Communicate with us (for example, on a social media platform or by sending us an email);
  • Provide personal information to us on Silver Lake’s social media pages; or
  • Otherwise voluntarily provide personal information to us through the Site or third-party websites, including education and employment history or other information provided in connection with an application for employment or internships at Silver Lake or its portfolio companies.

Information from Third Parties

We also may obtain personal information about you from third parties acting on our behalf, such as our website host, including the frequency with which you visit our Site and the links you use.

Device Information

We use server logs, which automatically record certain information from the devices of Site visitors, such as the number and frequency of visits, as well as IP addresses, time spent on the Site, and pages viewed.

Social Media Widgets

The Site may include social media functions, such as Twitter, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on the Site and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly.

Social media functions and widgets are hosted either by a third party or directly on the Site. Your interactions with the social media functions and widgets located on the Site are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on our Site, we strongly suggest you review the privacy policies of the companies that provide those functions and features.

How We Use the Information We Collect

We may use personal information in a number of ways, depending on the context, as follows:

  • To respond to your inquiry (for example, to contact you about your request or to ask a question about your inquiry);
  • To contact you for reasons related to offering and improving our services;
  • To provide announcements about future events and opportunities;
  • To audit the use of and develop our products and the Site, including through surveys;
  • To administer the Site, including to fix any formatting errors and improve its functionality;
  • To develop new products and services;
  • To perform market research;
  • To analyze our products, services, and websites;
  • To conduct due diligence activities in connection with corporate transactions or investments;
  • To meet legal requirements, including complying with court orders, valid discovery requests, and other appropriate legal mechanisms;
  • To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and assist in the prosecution of those responsible for that activity;
  • To provide information to representatives and advisors, including lawyers and accountants, to help us comply with legal, accounting, or security requirements;
  • To record and respond to any compliments, comments, or complaints from supporters or service users and to appropriately investigate and implement necessary changes; and
  • To evaluate candidates as part of job/internship applications and maintain necessary employee records.

We use the personal information for the purposes described above because either:

  • It is necessary to further our legitimate interests in providing services to our investors and other interested individuals, taking steps to protect and improve the Site and our IT systems, and other related matters that are not overridden by your interests, rights, and freedoms;
  • Where required, we have obtained your consent for the given purpose(s); or
  • It is necessary for compliance with our legal obligations.

Cookies & Tracking Technologies

Cookies are small text files that store information, such as your preferences and account settings, on the hard drive of your computer. Similar to many websites, if you have enabled cookies in your browser, Silver Lake, independently and through enabled third-party tools and programs, has the ability to collect certain technical information, such as originating IP address, browser type, browser language, browser location, how a user got to the Site (i.e., the URL of the last website the user visited), the next website the user visits, what pages are visited, the length of each Site visit, and the date and time of the user’s visit. This information helps us track trends and improve user experiences when visiting the Site.

How We Use Cookies and Other Tracking Technologies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Our website may use a variety of cookies or other tracking technologies (collectively hereinafter, “Cookies”):

  • Session Cookies: These are stored temporarily on your device whilst you browse our Site and are deleted from your device when you finish browsing.
  • Persistent Cookies: These are stored on your device after you have finished browsing our Site so that we can remember your preferences when you visit our website in the future.
  • Other tracking technologies: We may collect information from the Site through other automated means, such as web server logs, web beacons or tracking pixels, JavaScript, and other code that may run on your computer. 

First-party Cookies are set by us. Third-party Cookies are set by a third-party’s website and subject to the terms of the third-party’s privacy policy. We encourage you to review the privacy policies of such providers to understand their policies that apply to their collection and use of information.

We may use third-party analytic tools and technologies to analyze information received from our Cookies, including how visitors use the Site, to research our visitors’ demographics, interests, and behavior, to improve the Site, to provide visitors with customized services and information, and for other similar purposes.

Cookies We May Use

The table below describes the Cookies we use, their names, and what we use the Cookies for:

Cookie

Universal Analytics (Google)

Name

Analytics (Google)

_ga

_gid

_gat

Purpose

These Cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The Cookies collect information in a way that does not directly identify anyone, including the number of visitors to the website and any blog, where visitors have come to the website from and the pages they visited. Read Google’s overview of privacy and safeguarding data.

Expiry

2 years

 

Essential

borlabs-cookie

This Cookie is used to track and save your cookie preferences.

1 year

 

Amending Your Cookies Preferences and How We Respond to Do Not Track Signals

If you wish to restrict, block, or delete the Cookies which are set by our Site and third parties, you can do this using your browser settings to refuse all or some browser Cookies, or to alert you when websites set or access Cookies. If you set your browser preferences to block all Cookies, you may not be able to access all or parts of our Site. If you delete Cookies relating to our Site, including your Cookie preferences, you will be treated as a first-time visitor the next time you visit our Site. We do not respect a “do not track” signal from your browser.

Disclosure of Information

We may share your personal information with our affiliates, portfolio companies, and our advisors, for the purposes described in this Privacy Policy.

We may share personal information with third-party service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and email and providing us with technical, analytical, and hosting functions for the Site. As required by applicable law, we permit them to use or disclose personal information only as necessary to perform services on our behalf or comply with applicable legal requirements. 

In addition, we may disclose personal information about you (a) if we are required to do so by law or legal process (for example, due to a request from a law enforcement authority, a subpoena, court order, or discovery request); (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose us to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation); and (f) to our professional advisors, such as lawyers, accountants, insurers, and financial services, but only as is necessary for the performance of their services.

Protection of Personal Information

The security of your personal information is important to us. We employ technical, administrative, and physical security measures to protect any personal information you provide through the Site from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use the Site and send us such information at your own risk.

Other Websites, Links and Third-Party Technologies

Please note that this Privacy Policy applies only to the Site and not to any other third-party website that may link to or may be linked from it. We do not control the privacy policies or practices of other websites. If you follow links to websites not affiliated or controlled by Silver Lake, you should review their privacy policies, as this Privacy Policy no longer applies – i.e., the policies and practices of other websites and other parties are governed by their respective privacy policies. Silver Lake does not guarantee and is not responsible for the privacy or security of these other sites, including the accuracy, completeness, or reliability of their information. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

Please be advised that the virtual data room portals that can be accessed through links on the Site by investors in funds managed by Silver Lake are maintained by our third-party service providers, FIS Data Systems (previously SunGard DX) and Intralinks. FIS Data Systems’ and Intralinks’s respective privacy policies apply to those portals and to the personal information you provide in activating and using your account to access those portals. FIS Data Systems and Intralinks inform us of who has access to the portals they operate and each user’s usage of the portals. You can review FIS Data Systems’ privacy policy for the portal [here] and Intralinks’s privacy policy for the portal [here].  We encourage you to review those privacy policies.

Providing Personal Information through the Site

This Site is hosted in the United States.  If you access this Site from outside the United States, you are voluntarily transferring your personal information to the United States, a jurisdiction which does not offer the same type of protection to the personal information of individuals as the UK and countries within the European Economic Area (“EEA”).

Transfers of Your Personal Information

Some of the third parties listed in the “disclosure of information” section may be located in jurisdictions outside of the UK or the EEA.

If you are located in the UK or EEA, we will comply with applicable legal requirements to provide adequate protection for the transfer of personal information to recipients in countries outside of the UK and EEA respectively. In all such cases, we will only transfer your personal information if:

  • The country to which the personal information will be transferred has been granted an adequacy decision by the UK government (for transfers of UK data subjects’ personal data) or the European Commission (for transfers of EEA data subjects’ personal data);
  • We have put in place appropriate safeguards in respect of the transfer, for example the Standard Contractual Clauses; or
  • In the absence of an adequacy decision and where it is not possible to implement appropriate safeguards, we have another lawful basis for doing so.

If you are located in the UK or EEA you also may request a copy of the safeguards that we have put in place in respect of transfers of personal information by contacting us as described in the How to Contact Us section below.

How Long We Keep Your Personal Information

The time period for which we keep personal information depends on the purpose for which we collected it. In all cases we keep it for as long as reasonably necessary to fulfil the purposes for which we collected it. We will then delete the personal information, unless we are legally required to retain it, if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes), or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Subject to any applicable legal requirements, we typically retain personal information as follows:

  • Personal information you provide to us through our Site: We keep this personal information for as long as necessary in order to fulfil the purpose for which you provided it to us, which will generally not exceed six years from the date you provided the data, and for a short further period in case you send us further requests.
  • Personal information you provide when you sign up to receive direct marketing communications: We keep most of this personal information for the duration of our relationship with you until you opt-out or we do not have any contact with you for a long period of time.
  • Personal information collected for analytics purposes: We keep this personal information for a short period of time necessary for us to carry out the analytics.
  • Website logs: We keep Site audit logs, which may contain your personal information, for several months.

Your Rights

If you are located in the UK or EEA, you may, depending on the circumstances, have the following rights in relation to personal information that we hold about you:

  • To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
  • To request that we rectify or update your personal information that is inaccurate, incomplete, or outdated;
  • To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
  • To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted (for example, a request that we update your personal information);
  • Where you have given us consent to process your personal information, to withdraw your consent;
  • To request that we provide a copy of your personal information to you or a third party in a structured, commonly used, and machine-readable format in certain circumstances;
  • To object to certain of our data processing, such as for direct marketing purposes; and
  • To lodge a complaint with the relevant data protection authority in your jurisdiction (for example, the Information Commissioner’s Office in the UK). If you would like to discuss your concern with us before contacting a data protection authority, please use our contact details below.

If you are located in the UK or EEA and you wish to exercise any of your data protection rights, or if you consider that we have processed your personal information in violation of applicable law, or have any concerns regarding your privacy, please contact us as detailed in the “How to Contact Us” section below. 

How to Contact Us

If you have any questions regarding this Privacy Policy, or wish to notify us of any errors or changes as to any personal information you provide us through the Site, you can write to us at Privacy Matters, Silver Lake, 2775 Sand Hill Road, Suite 100, Menlo Park, CA 94025, or at Broadbent House, 65 Grosvenor Street, London W1K3JH, United Kingdom, or email us at [email protected].

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California Privacy Notice

Last Updated: January 31, 2024

This California Privacy Notice (“CA Privacy Notice”) supplements the Privacy Policy and applies solely to California consumers, including our website visitors and personnel working on behalf of our institutional investors, portfolio companies, business partners and vendors, both online and offline.

This CA Privacy Notice does not apply to (i) Silver Lake personnel or job applicants seeking opportunities at Silver Lake or (ii) investor information collected, processed, sold, or disclosed pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act.

This CA Privacy Notice uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”).

Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this CA Privacy Notice) the following categories of personal information about you:

  • Identifiers: identifiers, such as a real name, postal address(es), unique personal identifier (such as a device identifier; cookies; beacons; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, passport number, driver’s license or state identification card number, date of birth, and other similar identifiers
  • Additional Data: This includes information subject to Cal. Civ. Code § 1798.80, such as your signature, physical characteristics, bank account number and other financial information, education information and medical information
  • Protected Classifications: characteristics of protected classifications under California or federal law, including but not limited to race, color, national origin, religion, age, sex, gender, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status
  • Commercial Information: commercial or investment information, including financial products or investment services considered, obtained, or purchased, and other investing or consuming histories or tendencies
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, browser type and version, search history, and information regarding your interaction with our websites and applications
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information, such as job title and salary
  • Inferences: inferences drawn from certain of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We may use (and may have used during the 12-month period prior to the Last Updated date of this CA Privacy Notice) the categories of personal information listed above for the purposes described in our Privacy Policy.  In addition, we use personal information for the following purposes, including “business purposes” as they are described in the CCPA:

  • Monitoring and managing our investments (including our portfolio companies) and advising on career opportunities and/or employment decisions at our portfolio companies, in accordance with applicable law
  • Complying with applicable laws or rules of local or foreign regulatory or law enforcement authorities
  • Recruiting efforts, including to identify potential job applicants for our portfolio companies and to evaluate candidates as part of job applications
  • Performing services, such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytics services, calculating and carrying out distributions, responding to inquiries and providing announcements about future events and opportunities
  • Auditing, including auditing related to California consumer interactions and transactions
  • Short-term, transient use
  • Helping to ensure security and integrity
  • Debugging to identify and repair errors that impair existing intended functionality, such as on our website
  • Undertaking internal research for technological development and demonstration
  • Undertaking activities to verify or maintain the quality of our services and/or to improve, upgrade, or enhance those services.

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information in accordance with the criteria described in the “How Long We Keep Your Personal Information” section of our Privacy Policy.

Sources of Personal Information

During the 12-month period prior to the Last Updated date of this CA Privacy Notice, we may have obtained personal information about you from the following categories of sources:

  • Directly from you, such as when you attend an event that we have organized or you provide information through surveys, emails, calls, forms, investor questionnaires, subscription agreements (other onboarding documents), your online data-site or investor reporting portal, and other features on our website, or interact with our social media accounts;
  • From your devices, such as when you visit our website or connect to our wireless network;
  • From your investor capital account;
  • Our affiliates;
  • Our portfolio companies;
  • Your employer;
  • Other individuals, such as in connection with a referral or reference;
  • Recruitment agencies we collaborate with to fulfil vacancies at our portfolio companies;
  • Businesses and counterparties that we are evaluating in connection with a potential investment, disposition, or other business opportunity;
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers;
  • Law firms and fund administrators involved in the subscription process;
  • Social networks or other third-party websites; and
  • Website analytics providers, such as Google Analytics.

How We Disclose Personal Information 

Silver Lake does not sell, or share for cross-context behavioral advertising purposes, personal information about CA consumers covered by this CA Privacy Notice.

During the 12-month period prior to the Last Updated date of this CA Privacy Notice, we may have disclosed the following categories of personal information about you for a business purpose to the following certain categories of third parties:

Category of Personal Information

Identifiers

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

Category of Personal Information

Additional Data Subject to Cal. Civ. Code § 1798.80

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

Category of Personal Information

Protected Classifications

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

Category of Personal Information

Commercial Information

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

Category of Personal Information

Online Activity

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

Category of Personal Information

Sensory Information

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

Category of Personal Information

Employment Information

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

Category of Personal Information

Inferences

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services to us, such as administrative agents, know-your-client service providers, and IT and software service providers
  • Other financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Persons holding a legal or beneficial interest relating to investors or acting in a fiduciary or representative capacity on their behalf
  • Partners and investors in our funds
  • Website analytics providers

In addition to the categories of third parties identified above, during the 12-month period prior to the Effective Date of this Notice, we may have disclosed personal information about Job Applicants to government entities (e.g., law enforcement authorities) and third parties in connection with corporate transactions, such as mergers, acquisitions or bankruptcy.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access:  You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, and disclosed about you.

Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

Deletion: You have the right to request that we delete certain personal information we have collected from you.  Please note that as a registered investment adviser, we are required by law to maintain certain records and may be unable to accommodate your request.

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  For questions or concerns about our privacy policies and practices, please contact us as described in the “How to Contact Us” section of our Privacy Policy, which can be found on our website at https://www.silverlake.com/privacy-policy.

How to Submit a Request

To submit an access, correction or deletion request on your own behalf or as an authorized agent, email us at [email protected] or call our toll-free number at (866) 994-0462.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you request access to, or correction or deletion of, your personal information, we may require you to provide certain information, such as your full name, email address, and phone number.  In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This CA Privacy Notice is available in alternative formats upon request.  Please contact [email protected] or our toll-free number at (866) 994-0462 between the hours of 9:00 am and 5:00 pm Pacific Time to request this CA Privacy Notice in an alternative format.

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California Job Applicant Privacy Notice

Effective Date: January 31, 2024

This California Job Applicant Privacy Notice (“Notice”) describes the categories of personal information Silver Lake Technology Management, L.L.C. and its affiliates (“Silver Lake” or “we”) collect about California residents who apply and/or are evaluated for jobs with Silver Lake (“Job Applicants”). Certain terms used in this Notice have the meanings given to them in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (the “CCPA”).

Collection and Use of Personal Information

Silver Lake may collect (and may have collected during the 12-month period prior to the Effective Date of this Notice) the following categories of personal information about Job Applicants:

  • Identifiers: identifiers, such as a real name, alias, postal address(es), telephone number, email address, Social Security number, passport number, driver’s license or state identification card number, date and/or place of birth, IP address, and other similar identifiers
  • Additional Data: This includes information subject to Cal. Civ. Code § 1798.80, such as your signature, physical characteristics or description, education information, financial information and medical information
  • Protected Classifications: characteristics of protected classifications under California or federal law, including but not limited to race, color, national origin, religion, age, sex, gender, marital status, medical condition, disability, citizenship status, and military and veteran status
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, browser type and version, search history, and information regarding your interaction with websites or applications
  • Sensory Information: audio, electronic, visual, and similar information
  • Employment Information: professional or employment-related information, such as information relating to your position (g., job title and job description) and talent management information (e.g., résumé information, references, occupation details, education details, certifications and professional associations, historical compensation details from previous employment (if voluntarily provided or as permitted by law), previous employment details, and pre-employment screening and background check information, including criminal records information)
  • Inferences: inferences drawn from certain of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

We may use (and may have used during the 12-month period prior to the Effective Date of this Notice) the personal information described above for the purpose of processing job applications, evaluating candidates for employment, and/or carrying out and supporting HR functions and activities, including as described below. In addition to these general HR purposes, the purposes listed below also include relevant “business purposes” as they are described in the CCPA.

  • Recruiting; processing job applications; performing background and other pre- employment checks; determining suitability for employment; determining physical and/or mental fitness for work; reviewing and evaluating applications; determining salary and other forms of compensation; providing references; reimbursing expenses; making travel arrangements; securing immigration statuses; reviewing hiring decisions; and providing access to facilities.
  • Ensuring business continuity; protecting the health and safety of our staff and others; safeguarding, monitoring, and maintaining our IT infrastructure, office equipment, facilities, and other property; detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you.
  • Operating and managing our IT, communications systems, and facilities, and monitoring the use of these resources; performing data analytics; improving our services; allocating and managing company assets and human resources; strategic planning; project management; compiling audit trails and other reporting tools; maintaining records relating to business activities, budgeting, and financial management; managing any investment in or transactions relating to our business; and providing senior management oversight of the firm.
  • Complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management, and resolution of health and safety matters; diversity monitoring and EEO reporting; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing complaints or claims; conducting investigations; and complying with internal policies and procedures.
  • Performing services.
  • Certain short-term, transient uses.
  • Helping to ensure security and integrity.
  • Debugging to identify and repair errors that impair existing intended functionality.
  • Undertaking internal research for technological development and demonstration.
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance them.

We do not collect or process sensitive personal information with the purpose of inferring characteristics about Job Applicants.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain personal information about Job Applicants for the time period reasonably necessary to achieve the purposes described in this Notice, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

Sources of Personal Information

During the 12-month period prior to the Effective Date of this Notice, we may have obtained personal information about Job Applicants from the following categories of sources:

  • Directly from you;
  • Your devices;
  • Other individuals, such as in connection with a referral or reference;
  • Your employer;
  • Our affiliates;
  • Vendors who provide services on our behalf;
  • Data analytics providers;
  • Actual and potential portfolio companies and others within our network;
  • Government entities;
  • Professional services organizations, such as recruitment agencies;
  • Social networks;
  • Public databases; and
  • Data brokers, such as background check services.

Disclosure of Personal Information

We do not sell, or share for cross-context behavioral advertising purposes, personal information about Job Applicants.

During the 12-month period prior to the Effective Date of this Notice, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information

Identifiers

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Partners and investors in our funds
  • Internet service providers and operating systems and platforms
  • Data analytics providers
  • Data brokers, such as background check services

Category of Personal Information

Additional Data Subject to Cal. Civ. Code § 1798.80

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Partners and investors in our funds
  • Internet service providers and operating systems and platforms
  • Data analytics providers
  • Data brokers, such as background check services

Category of Personal Information

Protected Classifications

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Partners and investors in our funds
  • Internet service providers and operating systems and platforms
  • Data analytics providers

Category of Personal Information

Online Activity

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Internet service providers and operating systems and platforms
  • Data analytics providers

Category of Personal Information

Sensory Information

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Partners and investors in our funds
  • Internet service providers and operating systems and platforms
  • Data analytics providers

Category of Personal Information

Employment Information

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Financial institutions, such as banks and insurers
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Partners and investors in our funds
  • Internet service providers and operating systems and platforms
  • Data analytics providers
  • Data brokers, such as background check services

Category of Personal Information

Inferences

Categories of Third Parties

  • Our affiliates
  • Vendors who provide services on our behalf
  • Professional services organizations, such as auditors, recruitment agencies, and law firms
  • Actual and potential portfolio companies and others within our network, purchasers thereof and potential co-investors, and each of their respective advisors
  • Partners and investors in our funds

In addition to the categories of third parties identified above, during the 12-month period prior to the Effective Date of this Notice, we may have disclosed personal information about Job Applicants to government entities (e.g., law enforcement authorities) and third parties in connection with corporate transactions, such as mergers, acquisitions or bankruptcy.

California Consumer Privacy Rights

If you are a Job Applicant, you have certain choices regarding your personal information, as described below.

  • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold or shared about you.
  • Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
  • Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request. To submit an access, correction or deletion request on your own behalf or as an authorized agent, email us at [email protected] or call our toll-free number at (866) 994-0462.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to, correction of or deletion of your personal information, we may require you to authenticate your email address and/or provide information about your job application or other interactions with us. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the Job Applicant whose personal information is the subject of the request.

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

How to Contact Us

If you have any questions regarding this California Job Applicant Privacy Notice or our privacy practices, please contact us at [email protected] or our toll-free number at (866) 994-0462.

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Modern Slavery Act Statement

Silver Lake Europe LLP (“SLE”)

OVERVIEW

In October 2015, the UK’s Modern Slavery Act (“MSA”) came into force, requiring large organisations doing business in the United Kingdom to produce a public “slavery and human trafficking statement”. The concept of “modern slavery” encapsulates behaviours such as forced, compulsory or coerced labour, deprivation of personal freedom or facilitating the movement of people for exploitation.

BUSINESS STRUCTURE

SLE acts as a sub-advisor to Silver Lake’s US affiliates in relation to the investment of European based assets of Silver Lake managed funds. SLE is based in the U.K. and authorised and regulated by the U.K. Financial Conduct Authority. 

Although SLE is not technically required to publish a statement under the MSA, we have decided to publish this statement on a voluntary basis. This statement covers our financial year ending 31 December 2022. This statement is published on behalf of SLE and references to “we” or “our” are to that entity.

SUPPLY CHAIN AND RISK ASSESSMENT

SLE takes a zero-tolerance approach to slavery and human trafficking in all its forms. We endeavour to ensure that our business and supply chains are conducted and managed responsibly, in line with the principles underpinning the MSA.

Given the nature of SLE’s advisory business, we believe there is a relatively low risk of slavery or human trafficking in connection with our activities. The goods and services we typically procure are limited to areas such as office equipment, IT, professional services, facility management and catering.

Nonetheless, we understand that no business is completely risk-free and so, consistent with the principles of the MSA and as part of our initiative to identify and manage risk:

We continually look to better (a) identify, assess and monitor potential higher risk areas in the supply chains to our business, (b) mitigate the risk of slavery and human trafficking occurring in these supply chains through enhanced contract terms (to the extent appropriate and obtainable), (c) train relevant employees as to these risks and the need to manage them and (d) protect whistle blowers (please see below for further information on our Whistleblowing procedures).  

 Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.  

POLICIES

A number of our existing policies and procedures support our commitment in this area. These include:

  • Compliance Manual, covering a number of different areas, which underpins our standards of behaviour and expectations of good business practice for all of our employees;
  • Anti-bribery and Corruption Policy and Gifts and Entertainment Policy, which set out our zero-tolerance approach towards the receipt or request of bribes and other corrupt behaviour; and
  •  Whistleblowing procedure, which includes both internal and external contact information for reporting malpractice and raising concerns and allows for any actual or suspected issues to be raised in a confidential manner.
  • We proactively support community organisations and develop relationships with organisations that are working to address issues that are a priority for our firm. Silver Lake supports community and equal opportunity initiatives, such as SEO London’s ‘Careers’ program, which the firm participates in.

IMPLEMENTATION

Our SLE legal and compliance team take responsibility for implementing the objectives considered in this statement, monitoring progress of our efforts in this area and issues (should they arise) and report back to SLE’s Management Committee directly as appropriate.

Since our first MSA statement was published, we have used the following key performance indicators to track our progress toward increasing the awareness of and protecting against slavery and human trafficking arising in, or the supply chains to, our business:

  • We provide training on slavery, human trafficking and the MSA to relevant SLE personnel (see below);
  • We have incorporated a MSA section into our Silver Lake Europe LLP Compliance Manual, which is provided to all SLE employees; and
  • We review suppliers to our business and the terms which we work with them on (see above).

These metrics will continue to be used going forward.

TRAINING

Our SLE legal and compliance team provide training to relevant SLE personnel to educate them on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place in our business or supply chains.

A MSA update is included in our annual compliance refresher, which highlights the key issues employees should be aware of and provides an overview of the key legislative framework in this area.

MONITORING AND REPORTING

If issues are identified in relation to modern slavery or human trafficking, these should be immediately reported to our legal and compliance team.

More general issues in relation to the running of this policy are reported back to the Management Committee as appropriate.

This statement is reviewed annually and is published on our website – https://www.silverlake.com/modern-slavery-act-statement.

MANAGEMENT COMMITTEE APPROVAL

Silver Lake Europe LLP Management Committee approved this statement on 27 June 2023.

This statement is made on a voluntary basis pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes SLE’s slavery and human trafficking statement for the financial year ending 31 December 2022.

Date: 27 June 2023

Next review date: June 2024

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Transparency in Coverage

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

https://www.cigna.com/legal/compliance/machine-readable-files

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UK Recruitment Process Privacy Notice

Last Updated: January 31, 2024

This Privacy Notice describes how Silver Lake Europe LLP (“Silver Lake” or “we”) collects and uses the personal data of prospective personnel for Silver Lake and its portfolio companies in connection with recruitment by the firm (“Prospects” or “you”). Silver Lake is the data controller in respect of Prospect personal data.

If at any point you have questions about this notice or how we will treat your personal data, you should contact us using the details at the end of this notice.

Personal Data We Collect About You

We may collect (directly or indirectly), store, and use the following personal data about Prospects:

  • Personal details and characteristics including your name, address, and previous addresses, birthplace and date, phone numbers, e-mail address, passport details, photographs, and birth and marriage certificates.
  • Information contained in your C.V. and covering letter or provided as part of a background, reference, or credit check, including occupational details, current job title, current job description, previous employment details, office location, education details, qualifications, credit history, and other information from our application form.
  • Economic, financial, and insurance information including historic salary, benefits and incentives, income and financial information, tax situation, historic insurance package, personal accounts, and holdings.
  • Information about your use of technology resources including IP address.
  • Your communications with us including information you provide to us during interviews.
  • Tests or qualification exam results from any assessments that are required to work with us.

We may also collect (directly or indirectly), store, and use information that may identify or infer information about you in connection with more sensitive types of personal data including:

  • your race or ethnicity, religious beliefs, sexual orientation, political opinions and contributions, and trade union membership if you provide it to us.
  • information about your health, including any medical condition, health and sickness records.
  • your history, if any, of criminal convictions and offences.

You may be required to provide certain personal data to Silver Lake so that we may consider your suitability. If you fail to provide any personal data that is required, we may be unable to continue evaluating your suitability.

How We Collect Personal Data

We typically collect personal data about Prospects from the following sources:

  • you directly.
  • other Silver Lake affiliates.
  • recruitment agencies we collaborate with to fulfil vacancies, from which we may receive information including your resume/C.V., current and past employment, and other qualifications.
  • professional background check providers.
  • credit reference agencies.
  • your named referees, former employers and other references, from whom we collect information about your previous employment and suitability for the role you are applying for.
  • publicly accessible sources, including the internet and financial regulator registers, from which we collect information about your qualifications, regulatory authorisations, and news items involving you.
  • our server logs, which automatically record certain information from the devices of Site visitors, such as the number and frequency of visits, as well as IP addresses, time spent on the Site, and pages viewed.

How We Use Your Personal Data

We use the personal data that we collect, subject to applicable law and regulations, in the following ways:

  • Recruitment: managing and administering recruitment processes, carrying out background checks, making travel arrangements, assessing your skills, qualifications, and suitability for the vacancy you are applying for, communicating with you about the recruitment process, making offers to successful Prospects, personnel onboarding, and keeping records related to our hiring process to monitor and ensure fairness in our practices. We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business and recruiting personnel for Silver Lake and its portfolio companies.
  • Legal and compliance: compliance with legal and other requirements such as immigration, record-keeping, and reporting obligations, reviewing HR processes, political contributions, responding to legal process such as subpoenas and court orders, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures. We process personal data for these purposes on the basis that we are required to do so by law or it is necessary for the establishment, exercise, or defence of legal claims.
  • Communications, facilities and emergencies: facilitating communications with you, protecting the health and safety of anyone visiting our premises, and safeguarding office equipment, facilities, and other property. We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business, and administering, maintaining, and ensuring the security of our IT systems and premises.
  • Sensitive information: We may also collect certain types of sensitive personal data for specific purposes, including the collection of health or medical information for accessibility and ‘fit for work’ purposes and diversity-related personal data (such as gender, race, or ethnicity) for equal opportunity monitoring and reporting purposes. We do not collect your sensitive personal data unless we are required or permitted to do so by applicable law including in order to carry out our legal obligations or exercise rights in connection with your potential employment, it is needed in the public interests (such as for equal opportunities monitoring), or (in limited circumstances) you have, in accordance with applicable law, provided your explicit consent.
  • Criminal convictions information: Depending on the role you apply for, we may need to collect information about your criminal convictions history during the application process, if we intend to offer you employment (conditional on checks and any other conditions, such as references, being satisfactory).  Where the law allows or requires us to, we will carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for employment with us.  For example, we will need to carry out a Standard Disclosure and Barring Service Check for those wishing to work in our London office that will be discharging certain functions regulated by the Financial Conduct Authority.  We will inform you directly where we need to perform criminal convictions checks on you for your application.  We process personal data for these purposes on the basis that it is necessary for compliance with our legal obligations, where applicable, or on the basis of your explicit consent.

Data Sharing

We may share your personal data with Silver Lake Technology Management, L.L.C. and its portfolio companies for the purposes described in this Notice.

We may share personal data with service providers that perform services on our behalf such as payment service providers, benefits service providers, analytics providers, and hosting providers. As required by applicable law, we permit them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.

In addition, we may disclose personal data about you (a) if we are required to do so by law or legal process, for example due to a request from a law enforcement or other governmental authority, a subpoena, court order, or discovery request; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose Silver Lake to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; and (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will take appropriate steps to ensure it is adequately protected in compliance with the UK GDPR. We will usually do this by entering into standard contractual clauses (approved by the UK Information Commissioner’s Office) for data transfers with the recipient of your personal data.

You may request a copy of the safeguards that we have put in place in respect of cross-border transfers of personal data by contacting us as described in the ‘How to Contact Us’ section below.

Data Retention

Your personal data is retained for the duration of the relevant recruitment processes/discussions and as long as necessary thereafter to fulfil the purposes described above, which may be for up to six-years.

Retention periods may be extended if we are required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required by applicable law.

Retention periods may also be extended if you ask us to inform you about future job opportunities.

If your application is successful personal data provided to us in the recruitment process may be further processed by Silver Lake and retained as described in any applicable employee privacy notice.

Your Rights and Choices

Prospects applying for a position with Silver Lake in the UK may have the following rights in relation to that personal data:

  • To request confirmation of whether we process personal data relating to you and, if so, to request a copy of that personal data;
  • To request that we rectify or update your personal data that is inaccurate, incomplete, or outdated;
  • To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
  • To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;
  • Where you have given Silver Lake consent to process your personal data, to withdraw your consent;
  • To request that we provide a copy of your personal data to you or a third party in a structured, commonly used and machine-readable format in certain circumstances;
  • To object to certain of our data processing, such as for direct marketing purposes; and
  • To lodge a complaint with the relevant data protection authority in your jurisdiction (for example, the Information Commissioner’s Office in the UK).

If you wish to exercise any of your data protection rights, or if you consider that we have processed your personal data in violation of applicable law, please contact us as detailed in the “How to Contact Us” section below.

How to Contact Us

If you have any questions regarding this Privacy Policy, or wish to notify us of any errors or changes as to any personal data you provide us through the Site, you can write to us at Privacy Matters, Silver Lake, 2775 Sand Hill Road, Suite 100, Menlo Park, CA 94025, or at Broadbent House, 65 Grosvenor Street, London W1K3JH, United Kingdom, or e-mail us at [email protected].

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Walker Guidelines: Disclosures

Effective as of: December 8, 2023

In November 2007, a UK advisory group led by Sir David Walker published the Walker Guidelines for Disclosure and Transparency in Private Equity, which make recommendations to encourage greater disclosure and transparency by private equity firms investing in United Kingdom portfolio companies.

Silver Lake has voluntarily agreed to endeavour to conform on a “comply or explain” basis as part of its support of the Walker Guidelines. Silver Lake also intends to work alongside its United Kingdom portfolio companies covered by the Walker Guidelines to do the same.

Silver Lake has published this document in order to provide information on its UK private equity operations as part of its ongoing commitment to compliance with the Guidelines.

Silver Lake and Silver Lake Europe’s Private Equity Operations
Silver Lake is the global leader in technology investing, with approximately $101 billion in combined assets under management and committed capital and a team of professionals located around the world. Dedicated to the thesis that the dynamism and rapid pace of innovation in global technology demand intensely focused domain expertise, Silver Lake devotes its full scope of talent and intellectual capital to the singular mission of investing in the world’s leading technology, technology-enabled and related growth businesses. Applying the strategic insights of an experienced industry participant, the operating skill of a world-class management team, and sophisticated investing and structuring capabilities, Silver Lake leverages the deep knowledge and expertise of a global team based in North America, Europe and Asia.

Silver Lake Europe LLP (SLE) acts as a sub-advisor to Silver Lake’s US affiliates in relation to the investment of European based assets of Silver Lake managed funds. SLE is based in the U.K. and authorised and regulated by the U.K. Financial Conduct Authority.

Launched in 1999 as a specialist firm focused on technology company investments, Silver Lake has maintained its strategic discipline since its founding and engages in a synergistic and collaborative approach to investing across the following investment strategies:

  • Silver Lake Partners engages as a strategic market participant via large-scale investments in technology, technology-enabled and related growth businesses.
  • Silver Lake Alpine targets structured equity and debt investment opportunities in large-cap technology, technology-enabled and related growth businesses.
  • Silver Lake Waterman offers flexible growth capital to later-stage private companies in the technology, technology-enabled and related growth industries.
  • Silver Lake Long Term Capital is a 25-year long term strategy that furthers Silver Lake’s ability to partner with companies across all stages of growth.

The average holding period for our European private equity investments is expected to be between 4 and 6 years.

For more information on our investment approach and private equity operations, please see our website (https://www.silverlake.com).

For more information on our structure and investment approach and how we deal with conflicts of interest see our website (http://www.silverlake.com) and Silver Lake Technology Management L.L.C.’s public filings with the US Securities and Exchange Commission (http://www.sec.gov).

Portfolio Companies
As of the date of this document, we have approximately $101 billion in combined assets under management and committed capital and a team of professionals located around the world. Silver Lake’s portfolio companies collectively generate nearly $266 billion of revenue annually and employs approximately 540,000 people globally. For a list of our current portfolio companies, including those headquartered in the United Kingdom, please see our website (https://www.silverlake.com/portfolio/).

Conflicts of Interest
Silver Lake places significant importance on the prevention and management of conflicts of interest. Silver Lake has established and implemented a formal conflicts policy which ensures that it has appropriate systems and controls in place to identify, prevent and manage conflicts between its own interests and those of its clients and those of one client and another.

Silver Lake and SLE Team and Leadership
Silver Lake has a team of investment, operating and group professionals located in North America, Europe and Asia that manage Silver Lake’s investment activities across the globe.

For more information on the SLE team, based in London, including its leadership, please see our website (https://www.silverlake.com/team).

Limited Partners
We have established strong relationships with a diverse base of investors by type and geography. Many of these investors have invested with us since our inception and across multiple funds that we have sponsored. The commitments we receive come from a variety of institutions, with the largest percentage of our commitments for Silver Lake Partners V, Silver Lake Partners VI and Silver Lake Partners VII coming from public pensions and sovereign wealth funds. We also receive commitments from insurance companies, financial institutions, high net worth individuals, family offices and endowments and foundations, among other types of investors. 3% of these institutions are based in the United Kingdom, with the remaining 97% being based throughout the rest of the world.

Commitment to the Walker Guidelines
Silver Lake is supportive of the Walker Guidelines. SLE endeavours to conform to the Walker Guidelines on a “comply or explain” basis and intends to work alongside our United Kingdom portfolio companies covered by the Walker Guidelines to do the same.

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