Last revised: July 1, 2020
This Golub Capital BDC California Notice at Collection and Privacy Notice (“California Privacy Notice”) supplements the information contained in our Online Privacy Policy. It is delivered on behalf of Golub Capital BDC and our affiliates and governs certain personal information we collect from California residents (“you”) via www.golubcapitalbdc.com (“Website”).
We have adopted this California Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”). Please take the time to read and understand this California Privacy Notice.
Scope
Most of the personal information we collect about California residents is not covered by this California Privacy Notice at this time. The CCPA includes certain exemptions that may apply to our collection and processing of your personal information. Therefore, it is possible that not all personal information we collect from or about you is fully covered by the CCPA. Accordingly, this California Privacy Notice and the CCPA 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; and
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- To understand how we collect, use and share your nonpublic personal information in accordance with the GLBA, please read our Consumer Privacy Notice;
- Personal information that we collect about you in a business-to-business context, including when you are communicating with us as an employee of a business to whom we are providing or receiving a product or service.
In addition, publicly available information, de-identified data and aggregate California resident information (as those terms are used in the CCPA) are not personal information for purposes of the CCPA. This California Privacy Notice does not apply to such information.
Notice at Collection
We may collect the following categories of personal information from you:
- Identifiers
- Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
- Geolocation data
- Internet or other electronic network activity information
- Inferences drawn from other personal information
We may use your personal information for the following purposes:
- To present our Website and its contents to you
- To deliver the information, products and services you requested from us
- To reach out to you about and market or promote new information to you
- To communicate with you
- To help us improve our Website and deliver a more personalized experience
- To deliver targeted, interest-based and other advertising to you
- To carry out our obligations and enforce our rights
- In any other way we describe when you provide the information, or otherwise at your direction or with your consent
- As permitted by law or as we may notify you
Our Prior Collection, Use and Sharing of Personal Information
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 with whom we share 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 our Website. For more information regarding the personal information we collect from you via our Website, please read our Online Privacy Policy.
| Category of Personal Information | Categories of Sources From Which Collected | Business or Commercial Purpose for Collecting the PI | Categories of Third Parties and Other Entities With Whom We Share |
|---|---|---|---|
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How We Share Personal Information
In the last twelve months, we 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)
- Geolocation data
- Internet or other electronic network activity information
- Inferences drawn from other personal information
Sales of Personal Information
The CCPA defines the term “sale” very broadly. We do not currently sell your personal information for purposes of the CCPA. In the past 12 months, we have disclosed the following categories of personal information to third parties that provide services to us, such as website advertising and analytics services. Such prior disclosures may be considered a “sale” for purposes of the CCPA:
- Identifiers
- Categories of personal information described in Cal. Civ. Code Section 1798.80(e)
- Geolocation data
- Internet or other electronic network activity information
- Inferences drawn from other personal information
We do not have actual knowledge that we sell the personal information of minors under the age of 16.
Online Tracking and Advertising
As set out above, we and third parties collect and use your personal information for online tracking and other purposes.
Please click here to manage cookies.
If you opt-out 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. 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.
Your Rights as a California Resident
As a California resident, you have certain rights in relation to your personal information.
Right to Know
You have the right to know how we have collected, used and shared your personal information over the last twelve months. Specifically, you 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 or sell your personal information.
- The categories of third parties with whom we share your personal information.
- The categories of personal information that we disclosed for a business purpose and the categories of third parties to whom your personal information was disclosed for a business purpose.
- The categories of personal information we have sold to third parties and the categories of third parties to whom we have sold your personal information.
In addition, you have the right to know the specific pieces of personal information we have collected about you over the last twelve months.
Right to Make a Deletion Request
You 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 to delete your personal information.
Right to Opt-Out of Sales of your Personal Information
You have the right to opt-out of the sale of your personal information.
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 rights to know, access, or delete your personal information, please submit a request to us by clicking here, call us at +1-888-914-9661 (PIN Code: 59654) or contact us at compliance@golubcapital.com.
Information for Authorized Agents
You can authorize a person registered with the California Secretary of State (“Authorized Agent”) to exercise your California privacy rights on your behalf. To submit a request to Golub Capital on behalf of another person as an Authorized Agent, please submit a request to us by clicking here, call us at +1-888-914-9661 (PIN Code: 59654) or contact us at compliance@golubcapital.com.
Verifying Your Requests
We only respond to requests that you make which are “verifiable.” To verify your requests, we may require authentication of you or the Authorized Agent acting on your behalf that is reasonable in light of the nature of the personal information requested.
We may need additional information from you to verify your request. In order to verify your request, we may need to obtain additional information about you to match the information we already have about you. If you provide us with new personal information that we did not already have about you, we will use it solely for the purposes 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 request, we will let you know.
Responding To Your Requests
We aim to promptly verify your requests and respond to your requests within 45 days of receipt, but may require up to a total of 90 days to respond to your requests. If we require additional time beyond the initial 45 days and that time is reasonably necessary, 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.
Do Not Track
We rely on a third party service provider to implement a tool in an effort to recognize and honor “do not track signals.”
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 compliance@golubcapital.com