Privacy Policy

This website privacy policy (this “Privacy Policy”) applies to https://waltonst.com (the “Site”), which provides information about Walton Street Capital, L.L.C. and our affiliates (together, “Walton Street,” “we,” “us,” or “our”). We are committed to respecting the privacy of all users of the Site. This Privacy Policy only applies to information Walton Street may collect from visitors to the Site. If you are a California consumer, for more information about your privacy rights, please see the California Consumer Privacy Statement section of this Privacy Policy. This Privacy Policy is incorporated into, and is a part of, the Terms of Use, which govern your use of the Site in general. By entering and using the Site, you acknowledge your acceptance of, and agree to be bound by, this Privacy Policy, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use the Site or provide your personal details to us.

We have established and implemented this Privacy Policy to inform you, the user of the Site, of the type of personal information of identifiable individuals (“PI”) collected by us and how we use, maintain, disclose, and protect such information. Please read this Privacy Policy carefully.

Except where EU laws apply to the processing of your PI, by providing such information to us, you signify your acceptance of this Privacy Policy and agree that are permitted to collect, use, and disclose your PI as described in this Privacy Policy.

This Privacy Policy applies only to the public sections of the Site. If you are permitted access (i.e., you have received credentials to access information provided to investors) to Walton Street’s private, password protected investor website (the “Investor Portal”), the terms of your subscription agreement will control our use of any information provided by you. If you have not received a password to access the Investor Portal, you agree not to attempt to access the Investor Portal.

Walton Street reserves the right to amend this Privacy Policy in its sole discretion from time to time. Walton Street will post any changes to this Privacy Policy on the Site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it, and such changes shall be effective immediately upon posting. If at any point we decide to collect PI or use any collected PI in a manner different from that stated at the time it was collected, we will notify applicable users. Except where EU laws apply to the processing of your PI, your provision of such information after any such changes constitutes your acceptance of the new terms and conditions.

We will use information only in accordance with this Privacy Policy under which the information was collected.

Information We Collect

You may choose to contact Walton Street by email, in which case we will collect your name, email address, phone number, and any other information that you chose to provide to us. Please do not provide PI that you do not want us to have.

We do not use cookies or similar technologies on the Site.

Capacity

The Site is only intended for individuals who are at least 18 years of age and, by visiting the Site, you represent to us that you have the authority to visit the Site according to the Terms of Use. We do not (i) offer services and products to minors, (ii) knowingly encourage or solicit visitors to the Site who are under the age of 18, and (iii) intend to or knowingly collect PI from children under the age of 18 without parental consent. We follow all local legal requirements with respect to the collection and processing of a minor’s PI. If we learn we have collected or received PI from an individual under the age of 18 without parental consent, we will delete such information.

How We Use Information Collected

If you choose to provide information to Walton Street through or in connection with the Site or other means (for example, by email), we are permitted to use such information for our business purposes and the purpose you provided it to us. For example, if you provide your contact information in an inquiry to Walton Street, we will use your contact information to process and respond to that inquiry and any related activity that may result from your inquiry.

How We Share Information Collected

Walton Street is permitted (without your consent) to share your PI with Walton Street’s affiliates for the purposes described in this Privacy Policy.

Your PI will be shared with and processed by our affiliates and certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including, without limitation, professional advisors, recruitment firms, consultants, and data hosting providers. We may do so for the purposes of operating our business, delivering and improving the services we provide to you, as well as for other legitimate purposes permitted by applicable law such as sending communications related to our business. We also share PI for a variety of additional purposes including, but not limited to:

• Within Walton Street and among our affiliates for data processing or storage purposes;
• With business partners and suppliers to provide certain services and help facilitate transactions (including, without limitation, processing orders, event registrations, data storage, marketing communications, and customer support); and
• In response to a request from law enforcement, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements.

We will not sell your PI. If we share your PI with third parties performing services for us, or acting on our behalf, we will not allow them to use your information for other purposes, and we will contractually require them to protect your information. We take commercially reasonable efforts to ensure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.

In addition, Walton Street reserves the right to disclose personal information about you: (i) if we are required or permitted to do so by law, regulation or legal process, for example due to a court order or a request from a law enforcement or other governmental agencies; (ii) when we believe disclosure is necessary or appropriate to enforce or protect our rights in or otherwise with respect to, or the safety of, the Site, or to protect the safety or rights of other users of the Site; (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (iv) in connection with an investigation of suspected or actual fraudulent or other illegal activity; and (v) 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

The Site is controlled and operated from the United States and is not intended to be subject to the laws or jurisdiction of any country or territory other than that of the United States.

Your EU Rights

To the extent that the European Union (“EU”) and United Kingdom (“UK”) data protection laws apply to the processing of your PI, or to the extent that you are a resident of the UK, the EU, the Cayman Islands, or the European Economic Area (“EEA”), you have certain rights with respect to your PI, as outlined below.

You have the right to access the PI 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 privacy@waltonst.com.

• Access: You have the right to ask for a copy of the PI 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 PI if it is inaccurate or needs to be updated.
• Deletion: If you think that we should not be holding or processing your PI anymore, you may request that we delete it. Please note that this may not always be possible due to legal or regulatory obligations.
• Restrictions on use: You may request that we stop processing your PI (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 PI, 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 PI to another organization (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 PI 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 prior consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your PI (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.

If you believe that we have processed your PI in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

Your CCPA Consumer Rights

The California Consumer Privacy Act of 2018, as amended (the “CCPA”), provides California residents with certain data rights regarding what we do with your PI.

If you are an individual who resides in California and whose personal data is collected and processed by Walton Street, you may have the right to:

• Request that we disclose, free of charge, the categories and specifics of the PI we collect about you, the sources from which the PI was collected (and/or, if applicable, sell or otherwise disclose to a third party), and the business purposes) for collecting PI.
• Choose to opt-out of the sale of PI. Currently, however, Walton Street does not sell PI.
• Request that we delete the PI we have collected about you. Following our verification of the request, we will comply with the request and delete any or all the PI in our possession that we collected about you and/or any or all such PI in the possession of our service providers, unless otherwise restricted by law or regulation.
• Request that we correct inaccurate PI we have collected about you. Following our verification of the request, we will comply with the request and correct any or all the PI in our possession that we collected about you and/or any or all such PI in the possession of our service providers, unless otherwise restricted by law or regulation.
• Request that we limit the use of sensitive PI we have collected about you. Following our verification of the request, we will comply with the request and limit such the PI in our possession that we collected about you and/or any or all such PI in the possession of our service providers, unless otherwise restricted by law or regulation.

We will not discriminate against anyone for exercising their rights under the CCPA.

Information Security

We are committed to protecting your PI from unauthorized access and use. Access to your PI is restricted to those employees, agents, contractors, and other third parties who have a business need to know such information to provide our services to you. They will only process your personal data at our instruction and are subject to a duty of confidentiality. Our employees receive training to maintain the confidentiality, privacy, and security of your PI.

To help protect your PI, Walton Street maintains appropriate technical and organizational measures designed to protect your PI against loss or accidental, unlawful, or unauthorized, alteration, access, disclosure, or use. Unfortunately, no data transmission or storage system can be guaranteed to be completely secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.

How Long We Retain Information Collected

If Walton Street collects PI through the Site, the time period for which we keep PI depends on the purposes for which we collected it. We will keep your PI 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 PI, please contact privacy@waltonst.com.

How to Contact Walton Street About Privacy Matters

You may contact us in order to exercise any of your rights set forth in this Privacy Policy by calling this toll-free number (833) 712-1708,  contacting privacy@waltonst.com or using the “Get in touch” form on this Site.

If you would like to contact Walton Street for any reason concerning our privacy practices, please email us at privacy@waltonst.com.

Governing Law

This Privacy Policy forms a part of our Terms of Use and as such shall be governed by and construed in accordance with the laws of the State of Illinois, as further provided in the Terms of Use.

Updates to This Privacy Policy

Walton Street reserves the right to change or update portions of this Privacy Policy at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to this Privacy Policy. The revision date appearing below will identify the date of the last update or revision.

Last Updated: April 2023