California Consumer Privacy Statement

This California Consumer Privacy Statement (“Statement”) supplements the Hamilton Lane Privacy Notice. It applies solely to California consumers, including but not limited to, individuals who visit publicly-accessible sections of our Online Services, job applicants, and representatives of our institutional investors, vendors, and business partners. Capitalized terms not defined in this Statement shall have the respective meanings ascribed to such terms in the Hamilton Lane Privacy Notice (“Privacy Notice”).

This Statement does not apply to:

• Hamilton Lane personnel (e.g., employees, officers, or directors), their emergency contacts or their relatives for whom we administer benefits; or 
• Personal information collected, processed, sold or disclosed in connection with our provision of financial products or services pursuant to the Gramm-Leach-Bliley Act and its implementing regulations or the California Financial Information Privacy Act. 

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated date of this Statement) the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;
• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information;
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status;
• Commercial Information: commercial or investment information, including records of personal property, financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies;
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
• Sensory Information: audio, electronic, visual, or similar information;
• Employment Information: professional or employment-related information, such as information relating to your job position (e.g., job title, job description and office location), talent management information (e.g., résumé information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and pre-employment screening and background check information, including criminal records information) and emergency contact information;
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the Last Updated date of this Statement) your personal information for the purposes described in our Privacy Notice and for the following business purposes specified in the CCPA:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services;
• Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance; 
• Providing advertising and marketing services to you;
• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us;
• Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes; 
• Debugging to identify and repair errors that impair existing intended functionality;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

We do not collect or process sensitive personal information for purposes of inferring characteristics about consumers.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We will retain your personal information as described in the “Retention of Personal Information” section of our Privacy Notice. 

Sources of Personal Information 

During the 12-month period prior to the last updated date of this California Privacy Notice, we may have obtained personal information about you from the following categories of sources:

• Directly from you (e.g., if you communicate with us or attend one of our events) or the organization you represent (e.g., if you are a representative of an institutional investor) 
• Your devices, such as when you use our Online Services
• Our affiliates and subsidiaries
• Vendors who provide services on our behalf (e.g., fraud prevention and detection organizations)
• Our business partners (e.g., lenders to our funds, businesses we are evaluating in connection with a potential investment) and transaction counterparties
• Our institutional investors 
• Government entities
• Social networks
• Data brokers, such as background check services
• Publicly available sources
• Data analytics providers
• Online advertising services
• Recruiting and talent agencies

Sale or Sharing of Personal Information 

We do not sell personal information about California consumers in exchange for monetary compensation. As described in our Privacy Notice, we may disclose or make available your personal information by allowing certain third parties (such as providers of online advertising) to obtain your personal information, including via automated technologies on our website for cross-context behavioral advertising purposes. We may disclose your personal information to such third parties for analytics purposes or for the enhanced ability to serve you content and advertisements that may be of interest to you. Under the CCPA, these types of disclosures may be considered a “sale” when the personal information is exchanged for non-monetary consideration, or “sharing” when the personal information is disclosed for cross-context behavioral advertising purposes. You have the right to opt out of these disclosures of your information.  

We may “sell” or “share” (and may have “sold” or “shared” during the 12-month period prior to the last updated date of this California Privacy Notice) the following categories of personal information to providers of online advertising: Identifiers, Commercial Information, Online Activity, and Inferences. 

We do not have actual knowledge that we sell or share the personal information of minors under 16 years of age. We do not sell or share sensitive personal information.

Disclosure of Personal Information

During the 12-month period prior to the Last Updated date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

In addition to the categories of third parties identified above, during the 12-month period prior to the last updated date of this California Privacy Notice, we may have disclosed personal information about you with: (1) government entities, such as law enforcement authorities and regulators; (2) self-regulatory organizations; and (3) third parties in connection with an actual or proposed corporate transaction, such as a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below. 

• Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, and disclosed, and sold or shared about you, including the categories of personal information collected, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you. 
• Deletion: You have the right to request that we delete certain personal information we have collected from you. 
• Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
• Opt-Out of Sale or Sharing: You have the right to opt out the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising purposes.  

How to Submit a Request: To submit an access, deletion, or correction request, email us at privacy@hamiltonlane.com or call us at 1-866-443-8218. To opt-out of the sale or sharing of your personal information, you may submit a request here: Do Not Sell or Share My Personal Information. You may also submit a request to opt-out of the sale or sharing of your personal information by broadcasting the Global Privacy Control (“GPC”) signal. If you use the GPC, we will process it for your browser or device, but it will not apply outside of that specific browser or device. After using the GPC, if you clear the cookies in your browser or use another device, you will need to use the GPC again for us to process your opt-out request for that browser or device. To submit a request as an authorized agent on behalf of a consumer, please email us at privacy@hamiltonlane.com.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by asking you to sign in to your account. If you do not have an account with us and you request access to, correction of or deletion of your personal information, we may require you to verify your email address or certain of your information in our records, such as your name, address, phone number, CV information, details of a transaction, company name and job-details, or other information about your interactions with us. In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. 

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.