Investor privacy is a primary concern for StepStone. This privacy notice is being provided to explain StepStone’s practices for collecting and disclosing the personal information of clients to both affiliates of StepStone and nonaffiliated third parties. For purposes of this privacy notice, an affiliate is an entity that (i) controls StepStone, (ii) is controlled by StepStone, or (iii) is under common control with StepStone. Nonaffiliated third parties are parties who are not affiliates of StepStone.
Confidentiality of Personal Information
StepStone maintains the confidentiality of nonpublic personal information that a client provides to it. StepStone maintains physical, electronic and procedural safeguards to guard a client’s nonpublic personal information. All third parties that handle information must agree to follow the standards for confidentiality that StepStone has established. In addition, all people who work for StepStone are trained to handle a client’s information properly in order to maintain its security, and only employees who need to know nonpublic personal information about a client to provide services to such client have access to such information.
Categories of Nonpublic Personal Information that StepStone Collects
StepStone collects nonpublic personal information about clients from the following sources: (i) information it receives from clients on applications or other forms; and (ii) information about clients’ transactions with StepStone, its affiliates, or others.
Disclosure of Nonpublic Personal Information to Affiliates
Disclosure of Nonpublic Personal Information to Non-Affiliates
StepStone does not sell or market a client’s personal information to nonaffiliated third parties. StepStone’s intent is to respect the clients’ expectations that their personal information will be kept confidential. However, in order to serve the clients better, StepStone will disclose personal information to nonaffiliated third parties (including service providers to StepStone), but only to the extent necessary or appropriate for such third parties to perform services for the benefit of the client and only if StepStone believes that such personal information will be kept confidential by such third parties after such disclosure.
Additional Information About Categories of Nonpublic Personal Information that StepStone Discloses
Except as required by applicable law and described in this privacy notice, StepStone will not share any other nonpublic personal information about a client with its affiliates or nonaffiliated third parties.
Nonpublic Personal Information of Former Investors
This privacy notice and StepStone’s policy regarding treatment of nonpublic personal information of clients also apply to former clients.