Last revised: January 1, 2023
This Golub Capital California Notice at Collection and Privacy Notice (“California Privacy Notice”) is only applicable to California residents (“you”). It supplements the information contained in our Online Privacy Policy. It is delivered on behalf of Golub Capital and our affiliates and governs certain personal information we collect from you.
We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. (“CCPA”). Please take the time to read and understand this California Privacy Notice.
Scope
This California Privacy Notice covers personal information we collect automatically from California-resident individuals that visit our Website. In certain contexts, it also covers personal information we collect from California-resident representatives of companies and institutions with whom we communicate, do business or to whom we provide products or services.
There is other personal information that this California Privacy Notice does not cover. In some cases, that personal information may not be subject to the CCPA. In other cases, a different privacy notice may apply. Accordingly, this California Privacy Notice and/or the California privacy rights set out herein may not apply to you or to all of your personal information. For example, the following personal information is not covered by this California Privacy Notice:
- Personal information that is collected, processed, sold or disclosed pursuant to the federal Gramm Leach Bliley Act (“GLBA”) and implementing regulations;
- To understand how we collect, use and disclose your nonpublic personal information in accordance with the GLBA, please read our Consumer Privacy Notice
- Personal information we have from California residents in their capacity as current or former employees, personnel, or independent contractors of Golub Capital;
- Personal information we have from California residents who are emergency contacts of, or benefits recipients related to, current or former employees, personnel, or independent contractors of Golub Capital;
- Personal information we have from California residents in their capacity as owners, directors or officers of Golub Capital;
- Personal information we have from California residents in their capacity as current or former job applicants to Golub Capital;
- California-Resident Golub Capital Job Applicants: Please read Golub Capital’s California Resident Applicant Privacy Notice
- Personal information we collect from California residents when acting in their capacity as representatives of institutional clients or fund shareholders;
- If you interact with us in such capacity, please see our Notice of Privacy Policies and Practices for more information.
The following is not personal information for purposes of the CCPA: (i) publicly available information; (ii) lawfully obtained, truthful information that is a matter of public concern; (iii) deidentified consumer information about California residents; and (iv) aggregate consumer information about California residents (in each case, as those terms are used in the CCPA). This California Privacy Notice does not apply to such information.
Notice at Collection
The following table sets forth the categories of personal information we may collect from you as a business; the purposes for which we use it; and whether we “sell” or “share” it for purposes of the CCPA (as those terms are used in the CCPA). Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with us. For information on our receipt of personal information as a third party when we (i) conduct diligence on potential investments, and (ii) seek to identify new prospects and clients, please see Third Party Processing below.
| Category of Personal Information | Purpose for Collecting the Personal Information | Whether We “Share” the Category of Personal Information for Cross-Context Behavioral Advertising | Whether we “Sell” the Category of Personal Information |
| Identifiers and Categories in Cal. Civ. Code 1798.80(e), such as name, unique personal identifier, online identifier, IP address, email address, account name, phone number or signature |
|
Yes | No |
| Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories of tendencies |
|
Yes | No |
| Internet or other electronic network activity information, such as browsing history, search history or information regarding interaction with a website, app or advertisement |
|
Yes | No |
| Geolocation data, such as the state or country associated with your IP address
|
|
Yes | No |
| Audio, electronic, visual, thermal, olfactory or similar information, such as a recording of your voice or photo or video of you |
|
No | No |
| Professional or employment information, such as your job title or employer |
|
No | No |
| Inferences drawn from the information listed above to create a profile about a California resident reflecting their preferences, characteristics and other attributes |
|
Yes | No |
To opt-out of our sharing your personal information for cross-context behavioral advertising purposes, please click here.
Third Party Processing:
We may act as a third-party recipient of personal information about California-resident directors and officers of companies on which we or our affiliates are conducting pre-investment diligence. The categories of personal information we receive about such individuals may include: (i) Identifiers and Categories in Cal. Civ Code 1798.80(e), such as name, online identifier, or email address; (ii) Categories of Protected Classifications, such as race or veterans status; (iii) Internet or Other Network Activity, such as information regarding interaction with a website, app or advertisement; (iv) Geolocation data, such as physical or mailing address; (vi) Professional or employment information, such as current and former job title and employer; (vi) Inferences drawn from the above; and (vii) sensitive personal information. We use each category of personal information to conduct pre-investment diligence on the company associated with the California-resident individual, or as otherwise permitted or required by law. In connection with conducting diligence, we do not “share” or “sell” this personal information, as such terms are defined in the CCPA.
We may act as a third-party recipient of personal information about California-resident individuals or representatives of companies with whom we believe we may be interested in doing business. The categories of personal information we receive about such individuals may include: (i) Identifiers and Categories in Cal. Civ Code 1798.80(e), such as name, online identifier, or email address; (ii) Geolocation data, such as physical or mailing address; (iii) Professional or employment information, such as current and former job title and employer; and (iv) Inferences drawn from the above. We use each category of personal information to contact such individuals about products and services we believe may be of interest to them, or as otherwise permitted or required by law. We do not “share” or “sell” this personal information, as such terms are defined in the CCPA.
Data Retention: We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your personal information, we will consider the amount, nature and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process personal information and whether we can achieve those purposes through other means, and applicable legal requirements.
Our Prior Collection, Use and Disclosure of Personal Information During the Preceding 12 Months
The CCPA requires us to give you specific information about the categories of personal information we collect about you, the sources from which we have obtained that information, the purposes for which we collect it and the categories of entities to whom we disclose it. The table below sets out our relevant practices over the last twelve months. Our collection, use and disclosure of personal information depends on your relationship with us and your interaction with us.
| Category of Personal Information | Categories of Sources From Which Collected | Business or Commercial Purpose for Collecting PI | Categories of Third Parties and Other Entities With Whom We May Disclose |
| Identifiers and Categories in Cal. Civ. Code 1798.80(e), such as name, unique personal identifier, online identifier, IP address, email address, account name, phone number or signature |
|
|
|
| Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories of tendencies |
|
|
|
| Internet or other electronic network activity information, such as browsing history, search history or information regarding interaction with a website, app or advertisement |
|
|
|
| Geolocation data, such as the state or country associated with your IP address
|
|
|
|
| Audio, electronic, visual, thermal, olfactory or similar information, such as a recording of your voice or photo or video of you |
|
|
|
| Professional or employment information, such as your job title or employer |
|
|
|
| Inferences drawn from the information listed above to create a profile about a California resident reflecting their preferences, characteristics and other attributes |
|
|
|
How We Disclose Personal Information
In the past twelve months, we may have disclosed the following categories of personal information for business purposes:
- Identifiers
- Categories of Personal Information described in Cal. Civ. Code Section 1798.80(e)
- Commercial Information
- Internet or other electronic network activity information
- Geolocation data
- Audio, electronic, visual, thermal, olfactory or similar information
- Professional or employment information
- Inferences drawn from other personal information
Sales of Personal Information
We do not sell your personal information for purposes of the CCPA and have not done so in the past twelve months.
Sharing of Personal Information for Cross-Context Behavioral Advertising
In the past 12 months, we have shared the following categories of personal information with third-party companies for purposes of cross-context behavioral advertising in an effort to serve targeted, interest-based advertisements to you:
- Identifiers
- Categories of Personal Information described in Cal. Civ. Code Section 1798.80(e)
- Commercial Information
- Internet or other electronic network activity information
- Geolocation data
- Inferences drawn from other personal information
Minors Under the Age of 16
We do not have actual knowledge that we sell or share the personal information of minors under the age of 16.
Your Rights as a California Resident
As a California resident, you may have certain rights in relation to your personal information.
Right to Know
You may have the right to know how we have collected, used and disclosed your personal information. Specifically, you may have the right to know:
- The categories of personal information we have collected about you.
- The categories of sources from which we have collected your personal information.
- The business or commercial purpose for which we collect, sell or share your personal information.
- The categories of third parties to whom we have disclosed your personal information.
- The categories of personal information that we have sold or shared about you and the categories of third parties to whom it was sold or shared.
- The categories of personal information we have disclosed about you for a business purpose and the categories of persons to whom we have disclosed it.
In addition, you may have the right to know the specific pieces of personal information we have collected about you. Subject to certain limitations, you may request that we provide this information dating back to January 1, 2022.
Right to Make a Deletion Request
You may have the right to request that we delete your personal information that we have collected or received. Subject to certain exceptions, we must delete your personal information and direct our service providers and contractors to delete your personal information.
Right to Correct Inaccurate Personal Information
You may have the right to request that we correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
Right to Opt-Out of Sales of Personal Information
If we were to sell your personal information for purposes of the CCPA, you may have the right to opt-out of the sale of your personal information.
Right to Opt-Out of Sharing of Personal Information
You may have the right to opt-out of us sharing your personal information for cross-context behavioral advertising purposes.
Right to Limit Use and Disclosure of Sensitive Personal Information
Subject to certain exceptions, you may have the right to limit our use and disclosure of your sensitive personal information. We do not use or disclose your sensitive personal information in a manner that gives rise to this right.
Right to Non-Discrimination
You have the right not to be discriminated against by us for choosing to exercise your rights under the CCPA.
How to Exercise Your California Privacy Rights
If you wish to exercise your right to know, delete or correct inaccuracies in your personal information, please submit a request to us by calling us at +1-888-914-9661 (PIN Code: 59654) or contacting us at [email protected].
If you wish to exercise your right to opt-out of sharing of your personal information for cross-context behavioral advertising purposes, please click here. If you opt-out of cross-context behavioral advertising using this tool, an “opt-out cookie” will be placed on your device. Opt-out cookies are device- and browser- specific, meaning that you must opt-out across all of your devices and browsers in an effort to opt-out of cross-context behavioral advertising with Golub Capital. If you clear your cache or delete cookies from your browser, the opt-out cookie will also be deleted, meaning you will need to opt-out again.
“Do Not Track” Signals and Global Privacy Control (“GPC”) Signals
We rely on a third-party service provider to implement a tool in an effort to recognize and honor “do not track” and Global Privacy Control signals as requests to opt-out of “sharing” of personal information for cross-context behavioral advertising purposes.
Information for Authorized Agents
You can authorize a person (“Authorized Agent”) registered with the California Secretary of State to exercise your California privacy rights on your behalf. An Authorized Agent can also include a person who has power of attorney or is acting as a conservator. To submit a request to Golub Capital on behalf of another person as an Authorized Agent, please submit a request to us by calling us at +1-888-914-9661 (PIN Code: 59654) or contacting us at [email protected].
Verifying Your Requests
We only respond to your requests to know, access the specific pieces of personal information we have about you, delete and correct inaccurate personal information when we can verify that you are a California resident exercising your rights regarding your personal information.
We may need to ask you for personal information to verify your request so we can match it to the personal information we already have about you. We may also need to obtain additional information about you that we do not already have. If you provide us with new personal information that we do not already have about you, we will use it solely for the purpose of verifying your request. We will let you know via email if we need more information from you to verify your request. Please reply to our requests promptly.
We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.
If we cannot verify your identity, we will let you know.
Responding To Your Requests
We aim to promptly verify and respond to your requests within 45 days of receipt but may require a total of up to 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, we will let you know within the first 45 days.
We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).
If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.
Unless you tell us that you would like to receive a response via postal mail, we will respond to you via email regarding your requests to know and to access the specific pieces of personal information we have about you. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal information via postal mail rather than email, please let us know when submitting your request(s).
Limitations
The CCPA does not apply in full to all personal information we collect from California residents. As set out in “Scope” above, the CCPA is not fully applicable to much of the personal information we collect from California residents. Therefore, even if you are a California resident and submit a verifiable request, we may not be required to comply with your request.
We are only required to respond to certain requests twice in any twelve-month period. We are not required to provide you access to specific pieces of personal information more than twice in any twelve-month period. Similarly, we are not required to comply with your “requests to know” more than twice in any twelve-month period.
Changes to Our California Privacy Notice
From time to time, Golub Capital may update or revise this California Privacy Notice. If there are changes to the terms of this California Privacy Notice, documents containing the revised policy on the relevant website(s) will be updated.
How to Contact Us
If you have any questions or concerns about this California Privacy Notice, please contact us at [email protected]