No automated decision-making, including profiling, is used when processing your personal information.

Marketing

We will send you direct marketing communications based on your consent to keep you informed of our products and services in which you might be interested, or based on our legitimate business interests to tell you about certain events or to share news we believe you will be interested in. You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by emailing maketing@summitpartners.com or at any time choose not to receive our marketing communications by clicking on the “Unsubscribe” link provided in all our marketing emails.

Disclosure and Transfer of Personal Information

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through the Website; any transmission of information or data by you to or through the Website is at your sole risk.

Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including professional advisors, recruitment firms, consultants and data hosting providers. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards/derogations used, please contact Erin H. White at ewhite@summitpartners.com.

To the extent any personal information is transferred from Summit Partners, L.P. or an affiliate within the EEA to a Summit Partners, L.P. entity or an affiliate outside the EEA, this transfer is legitimised and your personal information is adequately protected under the terms of the EU controller-to-controller model contract clauses.

We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors on the basis of our legitimate interest.

Security and Retention of Personal Information

We are committed to protecting the personal information you entrust to us. We endeavour to implement robust and appropriate technologies and policies, and seek to ensure the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact Erin H. White at ewhite@summitpartners.com.

Capacity

The Website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to the Website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

Cookies

Information regarding how you access this Website and your hardware and software is automatically collected through the use of cookies or other technologies or tools. A cookie is a small text file that certain websites save on your device when you visit those websites. Cookies automatically collect information regarding how you access the Website (e.g., browser type, access times, and Internet Protocol (IP) address). We use cookies to improve the Website performance and to remember you when you return to the Website. You can confirm your website cookie preference through the interface in the cookies banner provided on the homepage of the Website. If you prefer not to receive cookies through the Website, you can also set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser when you visit the Website. If you turn off cookies (or refuse to accept a request to place a cookie), you may not have access to some features on the Website and some of our services.

More specifically, we use cookies for the following purposes:

(1) Strictly Necessary cookies used by the Website

We use strictly necessary cookies to provide users with the services available through the Website and to use some of their features. These necessary cookies are essential for using and navigating the Website. Without these cookies, basic functions of the Website would not work. Because these cookies are strictly necessary to deliver the Website, users cannot refuse them without impacting how the Website functions. For example, when a visitor logs into a password-protected area of the Website, we use a cookie to confirm the login status of that visitor in order to display password-protected content.

(2) Performance, Functional and Marketing Cookies used by the Website

Performance, functional and marketing cookies help website owners to understand how visitors interact with websites by collecting and reporting information both anonymously and at the individual level. The information generated by performance, functional and marketing cookies about your use of the Website will be transmitted to and stored directly by these service providers, who use the information to evaluate your use of the Website, including by noting the third-party website from which you arrive, analysing usage trends, measuring performance, assisting with fraud protection and providing certain features or information to you. Such third-party vendors may also transfer this information to other third parties where required to do so by law, or where such third parties process the information on such service provider’s behalf.

‍a. Performance Cookies

Performance cookies (anonymous cookies) help us understand how visitors interact with the Website by collecting and reporting information anonymously. Performance Cookies count visits and traffic sources so we can measure and improve the performance of the Website. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited the Website, and will not be able to monitor its performance. Please visit the Google Analytics privacy policy available at https://policies.google.com/privacy for additional information regarding how Google processes and protects your data collected through Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Brower Add-on by clicking here.

b. Functional Cookies

Functional cookies provide enhanced functionality and personalisation to the Website. They may be set by us or by third party providers whose services we have added to pages on the Website. If you do not allow these cookies then some or all of these services may not function properly.

c. Marketing Cookies

Marketing cookies are cookies that help website owners to understand how visitors interact with websites by collecting and reporting information at the individual level, if that individual has agreed to the use of cookies via the Website’s cookie notification banner. The Website utilizes opt-in third-party analytics services (such as those of HubSpot) to collect and analyse how users use the Website. For more information about HubSpot’s cookie and privacy policy, please visit https://legal.hubspot.com/privacy-policy

On the Website we use the cookies listed below:

You may wish to visit https://www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. The Website does not currently recognize or respond to browser initiated DNT signals. Should this change in the future, we will inform users through an updated version of this Privacy Policy.

Your Rights

You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact Erin H. White at ewhite@summitpartners.com.

• Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
• Correction: You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
• Deletion: If you think that we shouldn’t be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
• Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
• Portability: If you wish to transfer your personal information to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
• Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Notification of Changes

We reserve the right to amend this Privacy Policy from time to time by updating this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the Privacy Policy under which the information was collected.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact Erin White at ewhite@summitpartners.com or +1 617 824 1000.

Complaints

Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.

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California Website Privacy Policy

‍Last Updated: January 1, 2024

This California Website Privacy Policy supplements the Firm's Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Firm's Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this website privacy policy apply to?

This Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor), you will receive a separate privacy notice and that notice will govern that personal information. Information collected, used, or disclosed by Summit that is publicly available information from government records, de-identified or aggregated consumer information, or protected under other state and/or federal privacy laws, including the Gramm-Leach-Bliley Act, is exempt from the CCPA and is not addressed in this Website Privacy Policy.

What categories of personal information do we collect?

We collect limited types of personal information through our Website, as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:

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We do not knowingly sell or share the personal information of anyone under the age of 16 years old.

We do not collect or use sensitive personal information other than:

• To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
• As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
• As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
• For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
• To perform services on behalf of our business;
• To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
• To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

What categories of sources do we collect personal information from?

In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:

• Information from your communications with us in connection with this Website, including any updated notices provided by you.
• Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies (including third party statistic and analytic service cookies).
• We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

What business or commercial purposes do we collect personal information for?

We collect the above categories of personal information for one or more of the following business or commercial purposes:

• To perform services for you.
• To improve our Website and the products and services that we offer and notify you about changes to our products and services.
• To communicate with you, including responding to requests for information submitted by you through our Website.
• To keep a record of your relationship with us.
• Ongoing operations and administrative maintenance and other processes.
• To audit and verify the quality and effectiveness of our services and compliance.
• To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
• To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

We retain the categories of personal information set forth above in “What Categories of Personal Information Do We Collect?” section of this California Website Privacy Policy only as long as is reasonably necessary for those purposes set forth above in “What Business or Commercial Purpose Do We Collect Personal Information For?”, except as may be required under applicable law, court order or government regulations.

What categories of third parties do we share personal information with?

We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.

Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

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How do we keep personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect personal information about you in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our internal uses that are reasonably aligned with user expectation base on users relationship with us and our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:

• the categories of personal information we collected about you;
• the categories of sources from which the personal information is collected;
• our business or commercial purpose for collecting such personal information;
• the categories of third parties with whom we disclose the personal information;
• the specific pieces of personal information we have collected about you; and
• whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

Correction Right: You have the right to request that we correct any inaccuracies in the personal information we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact Us

For any requests relating to the exercise of your rights under the CCPA, or questions or concerns regarding our processing of your personal information, or our privacy policies and practices please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: 1-800-749-9411

Email us at the following email address: complianceofficer@summitpartners.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation with a 10-day timeframe please contact complianceofficer@summitpartners.com. Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact the Chief Compliance Officer of Summit Partners at complianceofficer@summitpartners.com with any questions about this California Website Privacy Policy.