California Consumer Privacy Act

Privacy Notice for Employees, Prospective Candidates and Other Personnel (California Residents)

Last Updated: April 2024

This Notice is being provided to you in satisfaction of certain of Sixth Street’s obligations under the California Consumer This Notice is being provided to you in satisfaction of certain of Sixth Street’s obligations under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and implementing regulations (collectively, the “CCPA”). This Privacy Notice describes the types of Personal Information we collect about California residents who are Sixth Street (1) employees, owners, directors, officers, contractors, advisers, servicers, or consultants (collectively, “Sixth Street Personnel”), (2) job applicants, (3) emergency contacts of Sixth Street Personnel, and (4) individuals related to Sixth Street Personnel for whom Sixth Street administers benefits (collectively with job applicants, Sixth Street Personnel, and emergency contacts, “Covered Individuals”). This Privacy Notice also describes the purposes for which we use such Personal Information.

Certain terms used in this Notice have the meaning given to them in the CCPA. This Notice is reviewed annually and may be updated from time to time.

Information We Collect And How We Use The Information

Over the course of your relationship with us, including during your job application process, at the beginning of your employment and during the course of your employment with us, it is routine for us to collect, process and store Personal Information about you. Personal Information does not include aggregate information nor any publicly available information as defined under the CCPA.

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information includes, but is not limited to, Sensitive Personal Information.
Sensitive Personal Information means Personal Information that reveals your social security, driver’s license, state identification card, or passport number; your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to your account; your precise geolocation; your racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless we are the intended recipient of the communication; your genetic data; the processing of your biometric information for the purpose of uniquely identifying you; and Personal Information collected that analyzes your health, sex life or sexual orientation.

We do not use or otherwise process your Sensitive Personal Information for the purposes of inferring characteristics about you nor do we use such information for any other purpose other than as noted above or as expressly permitted by the CCPA and its implementing regulations.

In the preceding twelve (12) months, we may have collected and/or processed the following categories of Personal Information and Sensitive Personal Information from you for the following business or commercial purposes and disclosed such Personal Information to the following categories of parties.

CATEGORIES OF PERSONAL INFORMATION AND SENSITIVE PERSONAL INFORMATION OBTAINED	BUSINESS OR COMMERCIAL PURPOSE(S) FOR PROCESSING	CATEGORIES OF THIRD PARTIES TO WHOM YOUR PERSONAL INFORMATION OR SENSITIVE PERSONAL INFORMATION MAY BE DISCLOSED
Identifiers and other contact information, including your name, work and personal contact details (including postal addresses, phone numbers, fax numbers and email addresses), and emergency contact information	Managing our workforce, including to process your employment application and/or administer the employment relationship Operating our facilities and preparing for and responding to emergencies Conducting business operations Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal	Other Sixth Street entities Service providers, such as benefit providers, payroll companies, insurance companies, information technology consultants, background check providers etc. External advisors, such as lawyers, accountants and auditors Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries
Sensitive Personal Information and other characteristics of protected classifications under California law, including age, date of birth, race, gender, sex, ethnicity, nationality, place of birth, citizenship status, disability, military and veteran status, marital status, and dependent information	Managing our workforce, including to process your employment application and/or administer the employment relationship Conducting business operations Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations	Other Sixth Street entities Service providers, such as benefit providers, payroll companies, insurance companies, information technology consultants, etc. External advisors, such as lawyers, accountants and auditors
Sensitive Personal Information for identification, including Social Security number, driver’s license or state identification card number, passport number and country of issuance, employee ID number, account name, CCTV footage, and photograph	Managing our workforce, including to process your employment application and/or administer the employment relationship Operating our facilities and preparing for and responding to emergencies Conducting business operations Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal	Other Sixth Street entities Service providers, such as benefit providers, payroll companies, insurance companies, information technology consultants, background check providers etc. External advisors, such as lawyers, accountants and auditors Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations
Professional or employment-related information relating to compensation, benefits and payroll information, including bank account details, salary-related information, tax-related information, benefits elections, health insurance information, insurance policy number, details regarding leaves of absence, and injuries or other medical issues	Managing our workforce, including to process your employment application and/or administer the employment relationship Conducting business operations Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal	Other Sixth Street entities Service providers, such as benefit providers, payroll companies, insurance companies, information technology consultants, etc. External advisors, such as lawyers, accountants and auditors Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations
Professional or employment-related information relating to your position, including job title, job description, training, performance management information (e.g., evaluations, offer letter), information regarding immigration status and eligibility for work, office location, and general location data regarding corporate travel destinations	Managing our workforce, including to process your employment application and/or administer the employment relationship Operating our facilities and preparing for and responding to emergencies Conducting business operations Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal	Other Sixth Street entities External advisors, such as lawyers, accountants and auditors Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations
Professional, employment-related and talent management information, including resume information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, and information received in connection with background checks and references	Managing our workforce, including to process your employment application and/or administer the employment relationship Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal	Other Sixth Street entities Third-Party Service Providers, such as information technology consultants and background check providers
Internet or other electronic network activity, including your use of Sixth Street’s IT resources, assigned equipment, IP address, user ID, online identifiers, the time and duration of internet and network connections and how you use technology resources, including emails you send/receive, websites browsing history, internet search history, software and files you download and voicemails you receive	Conducting business operations Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal	Other Sixth Street entities Service providers, such as information technology consultants External advisors, such as lawyers, accountants and auditors Where required by applicable laws or regulations, law enforcement agencies, parties to disputes, regulatory or tax authorities and other governmental or public agencies or authorities, including to respond to subpoenas or court orders, judicial processes or regulatory inquiries or investigations

Further Detail About Our Uses Of Personal Information Regarding Covered Individuals

As indicated in the table above, depending on your relationship with us, we may collect and use Personal Information and Sensitive Personal Information about Covered Individuals for certain business or commercial purposes. Below, we have provided further detail regarding each of these business or commercial purposes:

Managing our workforce: managing work activities and personnel generally, including recruiting; performing background checks; determining suitability for employment or promotion; determining physical and/or mental fitness for work; accommodating a disability or illness; reviewing and evaluating performance; determining eligibility for and processing salary increases, bonuses, and other incentive-based compensation; providing references; managing attendance, absences, leaves of absences, and vacations; administering payroll services; reimbursing expenses; administering health, dental, and other benefits; training and development; making travel arrangements; securing immigration status; monitoring staff; creating staff directories; investigating suspected misconduct or non-performance of duties; managing disciplinary matters, grievances, and terminations; reviewing staffing decisions; administering, organizing, and arranging participation in firm sponsored events or programs; and providing access to facilities.
Operating our facilities and preparing for and responding to emergencies: ensuring business continuity; protecting the health and safety of our staff and others; safeguarding, monitoring, and maintaining our IT infrastructure, office equipment, facilities, and other property; detecting or preventing theft or fraud, or attempted theft or fraud; and facilitating communication with you and your designated contacts in an emergency.
Conducting business operations: operating and managing our IT, communications systems and facilities, and monitoring the use of these resources; performing data analytics; improving our services; allocating and managing company assets and human resources; making insurance claims; strategic planning; project management; compiling audit trails and other reporting tools; maintaining records relating to business activities, budgeting, and financial management; and managing mergers, acquisitions, sales, reorganizations or disposals and integration with purchasers or sellers.
Satisfying legal and compliance obligations: complying with legal requirements, such as tax, record-keeping and reporting obligations; conducting audits, management and resolution of health and safety matters; complying with requests from government or other public authorities; responding to legal process such as subpoenas and court orders; pursuing legal rights and remedies; defending litigation and managing internal complaints or claims; conducting investigations; and complying with internal policies and procedures.
Detecting, investigating, and preventing activities that may violate our policies or be fraudulent or illegal: preventing, detecting and investigating security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, remediating such activity and prosecuting those responsible for that activity.

As described in our Employee Handbook, employees have no expectation of privacy in their use of, or the contents of, company-owned property, including voicemail, email and other business records or electronic media. Anything that is sent, received, or stored on any company-provided electronic media may be read, listened to, tracked or copied without notice.

Further Detail About How We May Disclose Your Personal Information

In the preceding twelve (12) months, we have neither sold Personal Information nor shared Personal Information to a third party for purposes of cross-context behavioral advertising. We do not have actual knowledge that we “sell” or “share” the Personal Information of individuals under the age of sixteen (16).

In addition to the purposes indicated in the table above, we may disclose Personal Information about you (a) if we are required or permitted to do so by law or legal process, for example, for the exercise of legal proceedings, a request from a law enforcement agency or if we believe in good faith that such disclosure is necessary to comply with a legal obligation or request or to enforce our terms and conditions, (b) when we believe disclosure is necessary or appropriate to protect the rights, property or safety of Sixth Street, our clients, another party, or the public, (c) in conjunction with (i) the making, management, or disposition of any of our investments or (ii) business continuity, or (d) to another party that acquires, or is interested in acquiring, all or part of our business in connection with a corporate sale, merger, reorganization, dissolution or similar event. We may also disclose Personal Information about you in other circumstances where we have your consent.

From What Sources Do We Collect Your Personal Information or Sensitive Personal Information

In the past twelve (12) months and going forward, we may collect Personal Information or Sensitive Personal Information from the following sources:

As provided by you, whether directly or indirectly, including via your devices;
Your prior employer and/or references;
Third-Party Service Providers, including recruiting agencies, background check providers, information technology consultants, etc.; or
Other publicly accessible sources

Retention Period

The time period for which we keep Personal Information or Sensitive Personal Information depends on the type of information or the purposes for which we collected it as set out in this Privacy Notice. In all cases we keep it for as long as necessary and proportionate to fulfill those purposes. We may retain personal information for longer where required by our regulatory obligations or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

How We Protect Your Information

We implement and maintain reasonable security appropriate to the nature of the Personal Information and Sensitive Personal Information that we collect, use, retain, transfer or otherwise process, including encrypting Personal Information and Sensitive Personal Information in transit and at rest. While we are committed to developing, implementing, maintaining, monitoring and updating a reasonable information security program, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to vulnerabilities, criminal exploits or other factors that cannot reasonably be prevented. Accordingly, while our information security program is reasonably designed to manage data security risks and thus help prevent data security incidents and breaches, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.

Your California Privacy Rights

As a California resident, you have the right to:

Know what Personal Information we collect 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 parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you (“Right to Know”);
Request deletion of your Personal Information that we have collected or maintained, subject to certain exceptions (“Right to Request Deletion”);
Request that we correct inaccurate Personal Information that we maintain about you (“Right to Correct”);
If applicable, to opt-out of the sale or sharing of your Personal Information (the “Right to Opt-Out”);
If we use or disclose your Sensitive Personal Information for reasons other than those permitted under the CCPA, to direct us to limit the use or disclosure of your Sensitive Personal Information by us (“Right to Limit Use of Sensitive Personal Information”); and
Not receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA, including your right not to be retaliated against for the exercise of these rights (“Right to be Free from Discrimination and Retaliation”).

Our responses to Right to Know requests will cover the Personal Information we have collected and maintain about the Covered Individual on or after January 1, 2022, or for a shorter period if requested by the Covered Individual, unless an exemption applies.

There may be some types of Personal Information that you provide to us that can be associated with your household, such as emergency contact information. Requests for access or deletion of household Personal Information must be made by each member of the household. We will verify each member of the household using the verification criteria explained below. If we are unable to verify the identity of each household member with the degree of certainty required, we will deny the request. In those cases, we will inform the requestor that their identity cannot be verified. In addition, we may not comply with requests that would infringe on the privacy rights of other individuals. We will notify you to explain the basis of our denial.

Exercising Your California Privacy Rights

Method to Submit Your Requests. If you wish to exercise any of the rights listed above or if you consider that we have processed your Personal Information in violation of applicable law, please email us at SixthStreetPrivacy@sixthstreet.com or call us at 888-306-1447. You can also submit requests online using the following link: https://sixthstreet.com/privacy-policy/.

Verification Procedures. To verify your identity and respond to your requests, we will ask you for at least two pieces of Personal Information and, for requests for specific pieces of Personal Information, we will ask you for at least three pieces of Personal Information. The information we require may vary depending on your relationship to us, and may include your full legal name, residential address, email, phone, as well information we may have on file about you or other information that may be necessary to verify your identity. If you are requesting on behalf of another individual, such as a member of your household, we may request additional information from you and/or such individual to verify their identity.

Using an Authorized Agent: If you are legally entitled to such rights, you may designate an agent to submit a request on your behalf. The agent can be a natural person or a business entity that is registered with the California Secretary of State. If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our agent verification process, including by providing written authorization signed by you directing the agent to act on your behalf.

How To Contact Us

If you have any questions regarding this Privacy Notice or our privacy practices, please email us at SixthStreetPrivacy@sixthstreet.com or call us at 888-306-1447.