Privacy Policy

This Privacy Policy sets forth the policies of Eminence Capital, LP (“Eminence Capital”) with respect to the collection, sharing and protection of non-public personal information you provide to Eminence Capital. These policies apply to individuals and Individual Retirement Accounts only and may be changed at any time, provided a notice of such change is given to you. Please read this Privacy Policy carefully.

You provide Eminence Capital with personal information, such as your address, social security number, assets, transaction and/or income information, for example, when you: (i) provide it to us in a subscription agreement and related documents; (ii) provide it to us in correspondence and conversations with Eminence Capital’s representatives; or (iii) make transactions with the investment funds managed by Eminence Capital or its affiliates, such as when you purchase securities in such investment funds, tell us where to send money or make a wire transfer.

Eminence Capital may disclose information about our investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or non-affiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so. We may also disclose information about your transactions and experiences with us to our affiliates for their everyday business purposes.

We may also disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent the Partnership has retained or may retain. If such a disclosure is made, Eminence Capital will require such third parties to treat your private information with confidentiality.

We do not share your information with non-affiliates for them to market to you. We may share information with our affiliates to market to you (e.g., other investment funds and investment management services). You may prevent this type of sharing by contacting Eminence Capital at ir@eminenecapital.com.

To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and buildings.

This web site may use “cookies,” which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from Eminence Capital’s web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of this web site. Cookies also help Eminence Capital diagnose problems with Eminence Capital’s computer systems.

Privacy Notice for California Consumers

Last updated: June 2023

This notice contains disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”). Terms defined in the CPRA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”). Consumers with disabilities may access this notice by contacting Eminence Capital, LP at 212-418-2100 or compliance@eminencecapital.com.

Information We Collect. In the past 12 months, we have collected and in some cases disclosed for a business purpose the following categories of personal information (“Personal Information”):

Personal Information does not include information that is publicly available, de-identified/ aggregated, or subject to HIPAA or GLBA.

We collect Personal Information from the following categories of sources: your communications with us and service providers, including, but not limited to, administrators and employment agencies.

We do not knowingly collect, solicit or sell Personal Information from anyone under the age of 18 without the prior consent of a parent or guardian.

Purpose for Collection and Use of Personal Information. We may collect or use Personal Information for one or more of the following purposes:

• Providing you with information about our products and services;
• Providing you with performance and other updates;
• One or more of the following business purposes:
  • Performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics;
  • Legal compliance;
  • Detecting and protecting against security incidents, fraud, and illegal activity;
  • Internal operations; and
  • Short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you.

Disclosing Personal Information. We may disclose Personal Information to:

• Service providers, including but not limited to: administrators, auditors, law firms, consultants, and employment agencies;
• Affiliates;
• Business partners;
• Legal or government regulatory authorities as required by applicable law; and
• Third parties to whom you or your agents authorize us to disclose such information in connection with services we provide to you.

In the past 12 months, we have not sold Personal Information to third parties.

Length of Time. We will keep your Personal Information for as long as necessary to comply with our regulatory obligations.

Rights of California Consumers. The CPRA provides a California consumer the following rights, subject to certain exceptions and limitations:

• The right to request: (a) the categories and specific pieces of Personal Information we collect about you; (b) the categories of sources from which we collect your Personal Information; (c) our business or commercial purposes for collecting, selling or sharing your Personal Information; (d) the categories of Personal Information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your Personal Information (if any) that we have either sold, shared, or disclosed.
• For certain categories of Personal Information, the right to request a list of what we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.
• The right to request that we delete your Personal Information, subject to certain exceptions.
• The right to opt out of our sale(s) (if any) of your Personal Information to third parties or sharing with such third parties for the purpose of cross-context behavioral advertising.
• The right to request we correct any inaccurate Personal Information maintained about you.
• The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
• The right not to receive discriminatory treatment for exercising your CPRA rights.

You may submit requests relating to your exercise of CPRA rights to us via:

phone 212-418-2100;
or
email compliance@eminencecapital.com.

You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and (2) sufficient detail that allows us to properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Questions
If you have questions regarding this Notice, please contact us at compliance@eminencecapital.com.