Last updated March 2026

1. Introduction

This website privacy policy (the “Website Privacy Policy”) describes the types of information Breckinridge Capital Advisors, Inc. (“Breckinridge”, “we”, “our”, “us”) receives about you when you visit https://www.breckinridge.com/ (the “Website”) or collects about you in other contexts. It describes what we do with information about you, how we protect it, and how you can contact us if you have a question or concern about the information we hold about you. Your use of this Website is also subject to the Terms & Conditions available on the Website.

If you are an investor or potential investor, or a representative thereof, information we collect about you and the privacy policy that governs the collection of such information is separate from this Website Privacy Policy and is available by contacting us via the methods described below (the “Investor Privacy Notice”).

If you have questions about this Website Privacy Policy, you may contact us using the methods described below in Section 12.

2. Personal information we collect about you 

We may collect and process the following personal information about you from a variety of sources, including directly from you, from third parties, and automatically on our Website.

• Identifiers, such as your name, address, email address, unique personal identifier, online identifier, Internet Protocol address, account name, Social Security number, driver’s license number, passport number or other similar identifiers;
• Personal information categories under California law, including name, signature, Social Security number, address, telephone number, passport number, driver's license or state identification card number, bank account number or other financial information (some personal information included in this category may overlap with other categories);
• Characteristics that are considered protected classifications under certain laws, such as national origin and marital status;
• Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
• Professional or employment information, such as your job title and place of work;
• Internet or other electronic network activity information, such as your internet protocol (IP) address, unique device identifiers, browser type and version, operating system and platform, and information about your interaction with the Website; and
• Geolocation data, such as geographic location information about a particular individual or device.

We may collect personal information that is considered “sensitive” under some data protection laws, such as your account log-in information if you log into our portal, or certain demographic information required by applicable law. When we do so, we use such information only for lawful purposes in compliance with applicable laws, and we do not use such information to infer characteristics about you. Where required by applicable law, we will obtain your consent prior to processing such information.

You may be asked to provide some of the personal information referred to in this Website Privacy Policy for one or more of the purposes described below. If you fail to provide this personal information when requested, and the information is necessary for us to comply with our legal or contractual obligations, we may not be able to meet the obligations placed on us. In all other cases, the provision of your personal information is voluntary.

3. How we use your personal information 

We collect personal information about you for the purposes of and pursuant to the legal bases of contract performance, legal compliance, legitimate interests and with your consent. These include:

• Where necessary for us to comply with legal or regulatory obligations, such as our obligations regarding know-your-client, anti-money laundering, tax purposes, fraud, terrorist financing and sanctions – this may involve collecting specific information about you where required by law and disclosing such information to applicable regulators, government bodies and tax authorities
• Where necessary for us to perform a contract with you or to take steps at your request before entering into a contract, including to: (i) provide you with information regarding our services, (ii) assist you and answer your requests, (iii) evaluate whether we can offer you a service and under what conditions
• Where necessary for other legitimate business interests, such as:
  • For our everyday business purposes - such as to provide and improve the content and functionality of the Website; maintain our business records; undertake business management, planning, statistical analysis, market research and marketing activities; manage our relationship with you; communicate with you; process your requests; protect our rights, property, and interests
  • For our direct marketing purposes (e.g., to notify you of new investment opportunities)
  • To support our portfolio companies, including in relation to their recruitment management
  • For our risk mitigation purposes - to protect against fraud and security risks, including through background screening
  • For Breckinridge product development, improvement and testing

In some cases, we rely on your consent to process your personal information.  We will only rely on your consent where we have specifically asked for it and, in each case, you will have the right to withdraw your consent at any time.  If you decline to provide or withdraw your consent to our use of your personal information and, under applicable law, we are relying on consent as the legal basis for its processing, there may be circumstances in which we will not be able to provide you with services or take action on your behalf.  

We do not use automated processing, including profiling, to make decisions that will have either legal or material effects on the individuals from whom we collect and process personal information.

4. To whom do we disclose personal information 

We disclose and have disclosed over the last 12 months personal information collected about you to select third parties. The categories of recipients include recipients to whom we may be required to disclose such information, for example, to legal or government regulatory authorities as required in connection with legal or regulatory matters, including in connection with background screens, claims, disputes, or litigation. We also disclose personal information to providers of professional advisory services, including consultants, legal advisors and accountants, and other third-party service providers.

In addition to the above, we may also share your personal information in connection with an asset sale, merger, bankruptcy, joint venture, financing, reorganization, or other business transaction, to enforce any applicable terms of service, to ensure the safety and security of Breckinridge, when you request we share certain information with third parties, and as necessary for us to establish, defend against, or otherwise manage a legal claim.

We do not sell personal information or share personal information for purposes of cross-context behavioral advertising.

5. How we protect personal information and data retention

Breckinridge maintains physical, electronic, and procedural safeguards intended to protect personal information about you from unauthorized access or use. Despite these security measures, no such measures can guarantee security or protect against unauthorized activity. To help Breckinridge protect your information, Breckinridge asks that you notify us as soon as possible if you are aware of any misuse of your personal information.

We will retain your personal information for as long as is necessary for the purposes set out in this Website Privacy Policy, or as long as we are legally required or permitted to do so. When deciding how long to retain your personal information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your information described above and whether we can achieve those purposes through other means. We may also retain your personal information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

6. Cookies and Other Online Tracking Technologies

We automatically collect certain information about your interaction with the Website. To do this, we may use cookies, web beacons/clear gifs, or other tracking technologies. You may control the way in which your devices permit the use of tracking technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some aspects of the Website to work incorrectly.

Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Website without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools → Internet Options → Browsing History → Delete to view manual and automatic options.

Do Not Track Signals: “Do not track” signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. While the Website does not respond to “do not track” signals in your web browser, we do not track the activity of users of the Website across online services and our Website. Please see our Cookie Policy for additional information.

7. Data subject rights 

Where applicable, depending on your jurisdiction and the laws that apply to our processing of your personal information, you may have certain data subject rights, including under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”), and similar laws in other states, in relation to personal information we have collected about you; these rights vary by jurisdiction and are subject to verification and any applicable exceptions, including for data subject to the federal financial privacy law:

(a) Right to Know/Access: You have the right to request that we disclose to you a copy of your personal information as well as certain information about our collection and use of personal information about you as described below:

(i) the specific pieces of personal information collected;

(ii) the categories of personal information collected;

(iii) the categories of sources from which the personal information is collected;

(iv) the purpose for collecting the personal information; and

(v) the categories of third parties with whom we have shared the personal information.

(b) Right to Correct or Delete: You have the right to request that we correct or delete the personal information.

(c) Right to Opt-Out of Sale/Sharing: You have the right to opt out of the sale of personal information or sharing of personal information for cross-context behavioral advertising—we do not sell personal information or share personal information for purposes of cross-context behavioral advertising, and so you are already opted out of such practices.

(d) Right to Object to/Restrict Processing: You have the right to object to or restrict the processing of your personal information under certain circumstances. 

(e) Right to Data Portability: You have the right to obtain a copy of your personal information in a portable format. 

We will not discriminate against you for exercising applicable data subject rights. Individuals may also have the right to lodge a complaint about the processing of personal information with an applicable data protection authority or other regulator. To exercise the rights described above, please submit a request to us via one of the contact methods identified below in Section 12. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

We will process your request within the time provided by applicable law.

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.

8. International Transfers

Because the Internet and our operations are global, your personal information that we collect or that you submit may be transferred to, processed in, and held in countries other than the one in which you reside. When we transfer personal information internationally, and to the extent required by applicable data protection laws, we rely on appropriate or suitable safeguards, including: where the relevant country or recipient has been deemed to provide an adequate level of protection for your information by relevant authorities; using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards; obtaining your consent to transfer your information after first informing you about the possible risks of such a transfer; transferring the information because it is necessary for the performance of (or to enter into) a contract between you and Breckinridge, or because the transfer is necessary for the performance of a contract between Breckinridge and a third party, and the contract was entered into in your interest; and transferring the information because it is necessary to establish, exercise or defend legal claims.

For more information on the safeguards we have in place, please contact us using the details below.

9. Third party websites

This Website may from time to time contain links to other external websites. This Website Privacy Policy does not apply to third-party websites. We do not control and are not responsible for the privacy practices or the content of third-party websites.

10. Children’s Privacy

The Website is not directed toward children under the age of 18. We do not promote our services online to minors, and we do not intentionally knowingly collect, sell, or share any personal information from any person under 18. If we become aware of having collected personal information from children under the age of 18 without valid consent, including as applicable from their respective parents or guardians, we will delete it as soon as practicable.

11. Updates to our website privacy policy

We may modify this Website Privacy Policy from time to time in which case we will update the “Last Updated” date at the top of this Website Privacy Policy. If we make changes that are material, we will take steps as required by law, including notifying you via the Website. The updated Website Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Website Privacy Policy.

12. Contact Us

Breckinridge may be contacted at the below for all questions relating to this Website Privacy Policy:

E-mail: privacy@breckinridge.com 
Phone: 877-443-2663