Please see our Notice at Collection below for a high-level overview of our privacy practices.

This Privacy Policy explains how ASG, LLC (“ASG”, “we”, “us”, or “our”) handles your personal information when you use our website at https://www.alpinesg.com/ or other products and services (collectively, the “Services”).

1. Personal Information We Collect

1.1 Personal information you provide when you use our Services:

• Contact and identification details, such as your first and last name, profession, company name, email address, telephone number and any other contact data that you may provide when you contact us through the website, via email, or otherwise.

• Communications that we exchange with you, including when you participate in any interactive features of the Services (such as by sending us a message or request through our “Contact” page, filling out a form, participating in a survey, applying for a job, communicating with us via third-party social media sites, requesting customer support, or otherwise communicating with us.)

• Business proposals. If you choose to submit a proposal to sell your company, we may process your name, contact details, company name, your industry, details of growth and revenue, and any other personal details which are contained in the contents of your proposal.

• Events: if you attend an ASG event, we may collect your personal information when you attend the event and exchange your details with us (for example, by providing your business card) and we may take photographs with your personal image.

• Job applicants: we may collect personal information from you when you enquire or apply for a vacancy with us, such as your name, contact details, curriculum vitae (such as, qualifications, previous employment history and profession activities), results of background checks (such as, references, qualifications, and to the extent permitted by law, criminal background checks (unspent convictions)).

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

1.2 Automatic data collection: We and our service providers may automatically log information about you, your computer or mobile device, and your interactions with our Services and our communications, such as:

• Log and Usage Information: the type of browser you use, access times, pages viewed, documents downloaded, your IP address, and the site you visited before navigating to our Services.

• Device Information, such as the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

• Information Collected by Cookies and Similar Tracking Technologies, such as your browsing actions and patterns; for example, your internet protocol address and other similar identifiers, browsing history, search history, information on your interaction with the website. We collect this personal information by using different technologies, including cookies and web beacons. Please visit our Cookie Policy for more information.

• Location information, such as your city, state, zip or postal code, to personalize content provided to you, or to show you prices and promotions.

1.3 Information we obtain from other sources: We may also obtain information about you from other sources. For example, we may collect information about you from third parties, including but not limited to publicly available sources.

• Information about portfolio companies and prospective portfolio companies. When we acquire a business, we will obtain personal information about the employees and other staff who work in that business to carry out and improve our business. In addition, we may collect personal information about third party companies we are considering acquiring and/or investing in to inform our decisions on whether to acquire and/or invest in the company. Such information may include publicly available information on founders and management teams and information on any interactions we have had with representatives of those companies.

• Social media information. We maintain pages on social media platforms, such as X and LinkedIn, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with your information through the platform, and we will treat such information in accordance with this Privacy Policy.

• Other sources. We obtain personal information from other third parties, such as analytics and marketing partners and publicly available sources, including from partners that help us advertise and market our Services.

2. How We Use Your Personal Information

We collect and process your personal information where we have a valid legal basis to do so. The legal basis for our collection and use of your personal information varies depending on the manner and purpose for which we collected it:

• Provide and maintain the Services. To perform a contract with you, or when it is in our legitimate business interests to do so, we will use personal information to operate, provide and maintain our Services, including to create and manage your account so you can log in, build a profile, and interact with us to benefit from our Services.

• Improve, monitor and personalize the Services. It is in our legitimate interests to improve and keep our Services safe, which includes protecting the security of our Services, and preventing and detecting security threats, fraud or other criminal or malicious activities.

• Communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages. To perform our contractual obligations to you, or when it is in our legitimate interests to do so, we will use your personal information to send you announcements, updates, security alerts, support and administrative messages, responses to your requests, questions, and feedback, and communicate with you about our Services, including by sending technical notices, updates, security alerts, support and administrative messages, and to respond to your comments, questions, and customer service requests.

• Evaluating portfolio companies or prospective portfolio companies. This processing is carried out in pursuance of our legitimate interests, namely to assess potential investments in or acquisitions of companies or businesses, and for related general business administration.

• Research and development. We use personal information to help us better understand how people use our Services and how we can develop, analyze and improve them where it is in our legitimate interests to do so. This includes monitoring and analyzing trends, usage, and activities in connection with our Services. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, and promote the Services.

• Compliance and protection. We use your personal information to comply with our legal obligations and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to:

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.

  • Enforce the terms and conditions that govern our Services.

  • Where we have a legitimate interest, to prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

  • Where we have a legitimate interest, to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).

3. How We Disclose Your Personal Information

We may disclose personal information to the following parties:

• Affiliates. We may disclose your personal information between and among ASG and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership for purposes consistent with this Privacy Policy.

• Service providers. We may disclose your personal information to third-party companies and individuals that provide services on our behalf or help us operate our Services (e.g. marketing platforms and customer relationship marketing services).

• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, auditors, bankers, advisors and insurers, where necessary in the course of the professional services that they render to us.

• Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

• Business transferees. We may share personal information as part of a proposed or completed corporate transaction, such as a merger, acquisition, reorganization, financing, asset sale, or similar transaction, or in the event of bankruptcy or related proceedings. Any such disclosure would be subject to appropriate confidentiality protections..

• Legal compliance. If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of ASG or others.

• With your instruction or permission. We may disclose personal information to relevant third parties, where you give us permission to do so in the course of your relationship with us from time to time.

• De-identified information. We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

4. International Data Transfers

In the context of providing you with our Services, we will store your personal information in the United States, and may transfer your personal information to our affiliates and service providers in jurisdictions outside the European Economic Area (“EEA”) and the United Kingdom (“UK”), such as the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.

5. Your Privacy Rights and Choices

Personal information requests. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:

• Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily-usable format.

• Correction of your personal information that is inaccurate or out of date.

• Deletion of your personal information when it is no longer needed for providing the Services or for other lawful purposes.

• Opt-out of the sale of your information or sharing of your personal information for interest-based advertising. By default, we do not sell or share your personal information. Please note that your opt out will be specific to the device and browser you use when you opt out. We do not have actual knowledge that we have sold or shared the personal information of children under the age of 16.

• Additional rights, such as the ability to object to the processing of your personal information and to request that we restrict how your personal information is processed.

To exercise the above rights, contact us as set out in the “How to Contact Us” section below. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Where you are requested to consent to the processing of your personal information by ASG, you have the right to withdraw your consent at any time.

In some instances, your rights and choices may be limited, such as where fulfilling your request would impair: the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.

Right to complain. Depending on where you reside, such as if you reside in the EEA or UK, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. Click here to find your local supervisory authority in the EEA. In the UK, the competent authority is the Information Commissioner’s Office.

6. Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be included on web pages or online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and disclosure of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

7. Security

We use organizational, technical, and administrative safeguards designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of any personal information we collect. While we strive to constantly improve these safeguards to protect your personal information, no security measures are failsafe and we cannot guarantee the security of your personal information.

8. Children’s Privacy

The Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Services from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it as soon as possible.

9. Retention of Personal Information

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information, and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

10. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by revising the date at the top of this Privacy Policy and posting it on the website. In some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

11. How to Contact Us

Responsible entity. ASG is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).

If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at [email protected]