Investor Privacy Policy
INVESTOR PRIVACY NOTICE (“INVESTOR PRIVACY NOTICE”)
This Investor Privacy Notice applies to the current, former and prospective investors (“Investors”) of Stripes, LLC (collectively, “Stripes,” “we,” “us,” or “our”). This Investor Privacy Notice (“Notice”) sets out how we collect, process, and use your personal information, including non-public information that may be governed by the Gramm-Leach-Bliley Act. Please note that this Notice, which can also be found on our website at stripes.co, may change from time to time and you should review it periodically.
If you are a resident of California, please review our Supplemental California Investor Privacy Notice, which is appended to this Investor Notice. If you have questions about which rights apply to you, or wish to exercise any such rights, you can contact us using the details set out below.
This Investor Notice is effective as of January 1, 2025.
STRIPES, LLC PRIVACY NOTICE | |||||||
At Stripes, we respect the privacy of our investors, and this Investor Privacy Notice governs how we collect, process, and use your personal information (data that identifies or could be used to identify, an individual person and is in the possession of, or is likely to come into the possession of, Stripes or our representatives or service providers). | |||||||
FACTS | WHAT DOES STRIPES DO WITH YOUR PERSONAL INFORMATION? | ||||||
Why? | Financial companies, including Stripes, choose how they share your non-public information and personal information (together, “personal information”). Federal law gives consumers the right to limit some but not all sharing of such information. Federal law also requires us to tell you how we collect, share, and protect your information. | ||||||
What? | The types of personal information we collect and share depend on the product or service we provide to you. This information can include:
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How? | All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ non-public and personal information; the reasons Stripes chooses to share such information; and whether you can limit this sharing. | ||||||
Reasons we can share your personal information | Does Stripesshare? | Can you limit this sharing? | |||||
For our everyday business purposes – such as to process your transactions or respond to court orders and legal investigations | Yes | No | |||||
For our marketing purposes – to offer our products and services to you | Yes | No | |||||
For joint marketing with other financial companies | No | We do not share | |||||
For our affiliates’ everyday business purposes – information about your transactions and experiences | Yes | No | |||||
For our affiliates’ everyday business purposes – information about your creditworthiness | No | We do not share | |||||
For our affiliates to market to you | Yes | Yes | |||||
For nonaffiliates to market to you | No | We don’t share | |||||
To limit our sharing: |
Please note: If you are a new customer, we can begin sharing your information thirty (30) days from the date we sent this notice. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. | ||||||
Questions? | Call: 212-823-0733 | ||||||
Who we are | |||||||
Who is providing this notice? | Stripes, LLC, a private equity firm registered with the U.S. Securities & Exchange Commission. | ||||||
What we do | |||||||
How does Stripes protect my personal information? | To protect your personal information from unauthorized access and use, we use physical, electronic and procedural security measures that comply with federal law. | ||||||
How does Stripes collect my personal information? | We collect your personal information, for example:
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Why can’t I limit all sharing? | In the U.S., federal law gives you the right to limit only:
State laws may give you additional rights to limit sharing. | ||||||
What happens when I limit sharing for an account I hold jointly with someone else? | Your choices will apply to everyone on your account – unless you tell us otherwise. | ||||||
Definitions | |||||||
Affiliates | Stripes, LLC, and any other companies related by common ownership or control. They can be financial and nonfinancial companies.
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Non-affiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies.
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Joint marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
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Supplemental California INVESTOR Privacy Notice
Effective as of January 1, 2025
This Supplemental California Investor Privacy Notice is provided in addition to the Investor Privacy Notice and any other privacy notice provided by Stripes, and explains Stripes’ online and offline collection, use, and disclosure of Personal Information relating to residents of the State of California (“consumers”, “you” or “your”) covered by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”) and provides information regarding how such California residents can exercise their rights under the CCPA. Any terms defined in the CCPA have the same meaning when used in this Investor California Privacy Notice.
This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. If you are an individual Stripes investor, our policies and practices regarding the collection and processing of your Personal Information are detailed in our Investor Privacy Notice provided above.
I. OUR COLLECTION, USE, RETENTION AND DISCLOSURE OF PERSONAL INFORMATION
- Sales and Sharing of Personal Information. We do not and have not sold any categories of Personal Information to third parties or shared any categories of Personal Information for the purpose of cross-context behavioral advertising.
- Collection, Sources and Use of Personal Information. We have collected and used the following categories of Personal Information from the following sources and for the following business purposes during the 12-month period prior to the “Effective as of” date of this Investor Privacy Notice:
Categories of Personal Information | Sources | Business Purposes |
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Identifiers, including name, contact details (including address, telephone number, email address and Internet Protocol address); cookies, beacons, pixel tags, mobile ad identifiers and similar technology, and other online identifiers. |
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Other records, including signature, physical characteristics or description; bank account number, other financial information (including accounts and transactions with other institutions); driver’s license or other state ID card number, or passport number; medical information and health insurance information; and verification documentation (including social security number, tax status, income and assets). | Directly from you; from automated tracking technology and monitoring tools; from within Stripes and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with business transactions. |
Protected classifications under California or federal law, including race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, disability, citizenship status, and military and veteran status. | Directly from you; from automated tracking technology and monitoring tools; from within Stripes and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with business transactions. |
Commercial information, including financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies. | Directly from you; from automated tracking technology and monitoring tools; from within Stripes and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with business transactions. |
Online activity, including your Internet and other electronic network activity information (e.g., browsing history, search history, and information regarding your interaction with websites, applications or advertisements). | Directly from you; from automated tracking technology and monitoring tools. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with business transactions. |
Employment Information, including your professional or employment-related information. | Directly from you; from within Stripes and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; from vendors; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with business transactions. |
Inferences, including those 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. | Stripes does not collect such information. | Stripes does not collect such information. |
Other information you create or provide to us, including the content of your communications with us. | Directly from you; from automated tracking technology and monitoring tools; from within Stripes and from our affiliates; from counterparties and intermediaries; from businesses that we are evaluating; and from recruiting sources. | Providing services; auditing and verifications; protecting our systems; to comply with legal obligations; and in connection with business transactions. |
- We do not knowingly collect or solicit any categories of Personal Information from any individual under the age of eighteen (18).
- Stripes may share anonymous or aggregated data in order to facilitate our business operations. To the extent such data constitutes anonymized or de-identified data under the CCPA and other applicable privacy and data protection laws, we will maintain and use such data without attempting to re-identify the data.
- We may process some of your Personal Information automatically, but we do not use computer algorithms to make automated decisions based on your Personal Information.
- Sensitive Personal Information. Sensitive Personal Information may include social security numbers, driver’s license numbers, passport numbers, and account credentials. To the extent we collect your Sensitive Personal Information, we will not use or disclose such information for purposes other than (i) to perform services/goods that you reasonably expect from us; (ii) to prevent, detect and investigate security incidents; (iii) to resist illegal actions directed at the business and prosecute defend our rights; (iv) to ensure the physical safety of others; (v) for short-term, transient use; (vi) to perform services necessary for the business; (vii) to verify and maintain the quality and safety of our product or services; and (viii) generally for purposes that do not infer characteristics about you.
- Retention of Personal Information. We retain Personal Information for as long as is reasonably necessary in connection with the purposes for which the Personal Information was collected or to comply with the law, prevent fraud, facilitate an investigation, defend against legal claims, or exercise our legal rights.
- Disclosures of Personal Information for Business Purposes. We have disclosed the following categories of Personal Information to the following categories of recipients for the following business purposes during the 12-month period prior to the “Effective as of” date of this California Investor Privacy Notice:
Business Purposes | Categories of Recipients | Categories of Personal Information |
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Performing and providing the services that we offer. | Service providers, contractors, advisors and others who provide services to us or on our behalf (together, “service providers and contractors”); professional services organizations, such as auditors, tax advisors, investment advisors, compliance consultants, and law firms (together, “professional advisors”); prospective lenders to or creditors of an entity in which we have or are considering investing (together, “lenders or creditors”). | Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information. |
Auditing and verifications, including but not limited to, verifying the quality and effectiveness of services and compliance. | Service providers and contractors; professional advisors; lenders or creditors. | Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information. |
Short-term, transient uses. | Service providers and contractors. | Identifiers; Other records; Protected classifications; Online activity. |
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity. | Service providers and contractors; government entities, including regulatory agencies and law enforcement (together, “government entities”); and professional advisors. | Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information. |
Debugging to identify and repair errors that impair existing intended functionality. | Service providers and contractors. | Identifiers; Other records; Online activity; Employment information; and Other information. |
To comply with legal obligations such as in connection with a valid court order, judicial subpoena or regulatory inquiry, and as required by law enforcement agencies, federal or state regulatory agencies, or self-regulatory organizations. | Government entities; counterparties and intermediaries; and professional advisors. | Identifiers; Other records; Protected classifications; Commercial information; Online activity; Employment information; and Other information. |
II. YOUR CALIFORNIA PRIVACY RIGHTS
a. Your CCPA Privacy Rights. You have certain choices regarding our use and disclosure of your Personal Information, as described below.
- Know: You have the right to request, twice in a 12-month period, that we (a) provide certain information about (1) the categories of Personal Information we have collected about you; (2) the categories of sources from which the Personal Information is collected; (3) the business or commercial purpose for collecting your Personal Information; and (4) the categories of third parties with whom we have shared your Personal Information; and/or (b) disclose to you the specific pieces of Personal Information we have collected, used, and disclosed about you during the past 12 months.
- Deletion: You have the right to request that we delete certain Personal Information we have collected from you and to tell our service providers to do the same.
- Correction: You have the right to request that we correct or amend certain Personal Information we maintain about you if it is inaccurate.
- Limit: You have the right to request that we limit the use and disclosure of Sensitive Personal Information we have collected. If Stripes collects any Sensitive Personal Information, it will use it only for purposes listed above in Section 1(d). As such, any Sensitive Personal Information that we collect does not come within this right to limit use.
- Opt-out: You have the right to opt-out of the sale of your Personal Information to third parties and/or the sharing of your Personal Information for certain purposes.
- Non-Discrimination: You have the right to not experience discriminatory treatment and we will not discriminate against you because you have exercised any California consumer privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
b. How to Submit a Request. You may submit a request by using one of the following methods.
Call: 212-823-0733
Email us: privacy@stripes.co
c. Verifying Your 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 we are successful in validating your identity, we will respond to your request within the time and in the manner required by CCPA. If we are unable to verify your identity, we will need to deny your request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.
- Consumer Verification. If you request to know, access, delete, and/or correct your Personal Information, we may require you to provide any of the following information: date of birth, state or country of residence, telephone number, email address, mailing address, or details of a transaction. 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. We will use the information you submit and the information we have in our systems to try to verify your identity and to match the Personal Information we have collected about you, if any, to your identity.
- Authorized Agent. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission (e.g., via a notarized letter) to do so, and (2) verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the request.