We are providing this supplemental CCPA notice ( “CCPA Notice”) pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and its implementing regulations (collectively the “CCPA”). This CCPA Notice only applies to Personal Data that is considered “personal information” as defined under CCPA and subject to the CCPA (namely, personal information of California residents who are employees or personnel of our institutional
investors). In particular, the CCPA and this CCPA Notice do not apply to Personal Data which is collected, disclosed, or otherwise processed pursuant to and subject to the Gramm-Leach-Bliley Act (“GLBA”), such as Personal Data of individual investors acting in their personal capacity. Supplemental information regarding our processing of Personal Data subject to the GLBA (including for individual investors acting in their personal capacity) is found in ou r U.S. Investor Data Privacy Notice.
For purposes of this CCPA Notice, the terms “sell”, “share”, and “consumer” shall have the meanings set forth in the CCPA. Please visit our California Consumer Privacy Statement located at https://www.blackstone.com/privacy/california-consumer-privacy-statement/ for more information, including the rights and choices that may be available to California residents
under the CCPA.
Categories of Personal Data collected. The categories of Personal Data to be collected about you in the context of your employer’s investment in a Fund or other investment vehicle are described in the section above titled “What personal data do we collect about you?” and may include:
- Identifiers, such as name, e-mail and postal address, and telephone;
- Information as defined by Cal. Civ. Code § 1798.80 , including state identification card number and financial information;
- Protected classifications, such as national origin, gender and citizenship status;
- Biometric information, for example, if we apply facial recognition technology to CCTV footage at a premises you visit;
- Internet or other electronic network activity information, including your use of our websites and investor platform;
- 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 aptitude;
- Professional or employment related information, such as the name of your employer or the organization you represent and your position, and details of any directorship or other offices you may hold, including your professional profile (including but not limited to public profiles you maintain on third party social media sites such as LinkedIn); and
- Sensitive Personal Data, such as citizenship, social security number, passport number, drivers’ license, or state identification card number.
Purposes for which the categories of Personal Data are collected and used. The purposes for which the categories of Personal Data are collected and used are provided in the section above titled “Why do we process your personal data?” and may include meeting our contractual obligations with our customers or clients, compliance with applicable laws, and any of the business purposes set forth in Cal. Civ. Code § 1798.140(e).
Whether we “sell” or “share” Personal Data. In the context of Personal Data we process about you when you represent an institutional investor in a Fund or other investment vehicle, we may disclose your Personal Data to third parties (such as online advertising services) or allow such third parties to collect your Personal Data via automated technologies on our websites and apps, in both cases for cross-context behavioral advertising purposes. Under California law, these kinds of disclosures may be considered a “sale” or “sharing” of your Personal Data. You have the right to opt out of these types of disclosures of your information. We may “sell” or “share” the following categories of Personal Data about you to online advertising services: (i) identifiers; (ii) commercial information; (iii) online activity; and (iv) inferences.
Retention of Personal Data. We will retain your Personal Data for the time period described in the “Retention and Deletion of your Information” section of the Data Privacy Notice.