Sixth Street | MtC Community Privacy Policy

Sixth Street More than Capital Community Privacy Notice

Last Updated: 30 May 2025

Our Commitment to Your Privacy

This Sixth Street More than Capital Community Privacy Notice (“Privacy Notice”) explains how Sixth Street (“we,” “us,” and/or “our”) collects, uses, and discloses information from individuals (“you” and/or “your”) who access and use our online More than Capital community or mobile or other downloadable applications (collectively, the “Community”).

This Privacy Notice should be read in conjunction with Sixth Street’s Website Privacy Policy (please see here) and any relevant privacy policies on the handling of employee data that may apply to your relationship with Sixth Street.

Information We Collect and How We Use It

In this Privacy Notice, “Personal Information” means any information related to an identified or identifiable individual or household and does not include data whereby personally identifiable information has been removed (such as anonymous data). We collect Personal Information in various ways as outlined in our Website Privacy Policy and relevant employee privacy notices. Personal Information collected, as it specifically relates to the Community, is outlined below. We may also obtain Personal Information from other parties, such as vendors, advisors and other business partners and publicly accessible directories and sources.

The following chart describes the categories of Personal Information we collect when you use the Community, where and why we collect it, and the categories of entities with which we disclose the Personal Information, if any. We may also collect, process and disclose Personal Information with your consent.

Categories of Personal Information We Collect

Source of Collection

Business Purpose of Collection and Use

Types of Third Parties With Which We Share Personal Information

Identifiers (e.g., name, email address, other contact information), and account information

Directly provided by you to us, including when you open an account with us through the Community

If you connect your social media account to your account or create or log into your account through a social media site, certain information from your social media account will be shared with us, which may include information that is part of your profile or your friends’ profiles

To facilitate our provision of the Community

Provide, maintain, and improve the Community and to enhance and personalize your experience

Send you technical notices, updates, security alerts, and support and administrative messages

Communicate with you about events and networking opportunities offered by Sixth Street and others, and provide news and information we think will be of interest to you

Maintain appropriate records for internal administrative purposes

Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations

Link or combine with information we get from the Community and from others to help understand your needs and provide you with better service

Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal

Service Providers, including Circle, Co, Inc. (“Circle”), the technology platform where the Community is hosted, in connection with the provision of the Community

Other Sixth Street entities

As otherwise disclosed in “How We Disclose the Information We Collect”

Personal Information relating to your interactions within the Community

When you submit information or content, such as by commenting on a blog or participating in online communities

When you interact with our Community, including members in the Community, or when you participate in any interactive features of the Community (e.g., sending us a message through the Community, participate in a contest or promotion)

When you communicate with other members through the Community,  we and our service provider, Circle, including its sub-processors  receive the content of the messages you send and receive and information about those messages, such as when it was sent or received, in connection with the provision of the Community

To facilitate our provision of the Community

Provide, maintain, and improve the Community and to enhance and personalize your experience

Send you technical notices, updates, security alerts, and support and administrative messages

Communicate with you about events and networking opportunities offered by Sixth Street and others, and provide news and information we think will be of interest to you

Maintain appropriate records for internal administrative purposes

Comply with our obligations, including legal, regulatory, due diligence, business operations, operational or fiscal obligations

Link or combine with information we get from the Community and from others to help understand your needs and provide you with better service

Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal

Service Providers, including Circle, in connection with the provision of the Community

Other Sixth Street entities

As otherwise disclosed in “How We Disclose the Information We Collect”

Payment information

When you make a purchase through the Community, your payment related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf

Process, complete, and maintain records on transactions

Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Sixth Street

Service Providers, including Circle, in connection with the provision of the Community

Location information

When you access or use the Community, we collect user-entered location data.

 

We may also collect approximate location based on your IP address

Provide, maintain, and improve the Community and to enhance and personalize your experience

Monitor and analyze trends, usage, effectiveness and activities in connection with the Community, including our offers, advertising, communications features, and customer service

Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal

Service Providers, including Circle, in connection with the provision of the Community

 

As otherwise disclosed in “How We Disclose the Information We Collect”

Professional or employment-related information (e.g., compensation, job position/title, or other information from CV) (to the extent shared with the Community)

Directly provided by you to the Community

To facilitate our provision of the Community

Provide, maintain, and improve the Community and to enhance and personalize your experience

Maintain appropriate records for internal administrative purposes

Link or combine with information we get from the Community and from others to help understand your needs and provide you with better service

Service Providers, including Circle, in connection with the provision of the Community

Other Sixth Street entities

As otherwise disclosed in “How We Disclose the Information We Collect”

Education information (e.g., level of education) (to the extent shared with the Community)

Directly provided by you to the Community

To facilitate our provision of the Community

Provide, maintain, and improve the Community and to enhance and personalize your experience

Maintain appropriate records for internal administrative purposes

Link or combine with information we get from the Community and from others to help understand your needs and provide you with better service

Service Providers, including Circle, in connection with the provision of the Community

Other Sixth Street entities

As otherwise disclosed in “How We Disclose the Information We Collect”

 

How We Disclose the Information We Collect

We disclose your Personal Information for the purposes described in this Privacy Notice (see above).

We disclose your Personal Information with service providers that perform services on our behalf, such as analytics providers and hosting providers.

In addition, we 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 connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in conjunction with (i) the making, management, or disposition of any of our investments, (ii) business continuity, or (iii) to another party that acquires, or is interested in acquiring, all or part of our business in connection to 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.

Links to Unaffiliated Websites

The Community may contain links to other websites. We have no control over and are not responsible for the privacy policies or practices of such websites. Whenever you link to another website, you may be asked to provide registration or other information. Please note that any Personal Information that you provide is going to another party, and therefore you should familiarize yourself with that party’s privacy policy or notice.

Accessibility

Sixth Street is committed to ensuring that our communications are accessible to individuals with disabilities. Individuals with disabilities can access this Privacy Notice in alternative formats by contacting us at the address, phone, or email address below. This website is designed to meet content accessibility guidelines. To submit accessibility-related requests or report barriers to accessibility, please contact us at 1-877-543-3198 or contact SixthStreetPrivacy@sixthstreet.com.

Cookie Notice

: Circle may collect cookies or similar technologies in the context of their administration of the platform. We encourage users to review Circle’s separate privacy notice (here) and cookie policy (here).]

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they do not track the user. Sixth Street does not change its practices, described elsewhere in this Privacy Notice, in response to DNT browser settings or signals. For information about DNT, visit www.allaboutdnt.org.

Other parties may collect Personal Information about your online activities over time and across different websites, including your access and use of services in the Community. This Privacy Notice does not apply to, and we are not responsible for, the practices of other parties that collect your Personal Information.

How Long We Keep Information

The time period for which we keep Personal Information depends on the purposes for which we collected it as set out in the Privacy Notice. In all cases we keep it for as long as necessary to fulfill those purposes, or for as long as we are required to do so for backups, archiving, and prevention of fraud and abuse. We will then delete this Personal Information unless we are required to preserve your Personal Information in connection with litigation, investigations and proceedings, or if a longer retention period is required or permitted by applicable law, or where we otherwise reasonably believe that we have a legitimate reason to do so.

EEA-Specific Disclosures

The information below is intended only for users interacting with the Community who are located in the European Economic Area (“EEA”), UK or Switzerland.

Controller Details

Unless stated otherwise, Sixth Street is the controller in respect of Personal Information collected through the Community, as outlined above, and can be contacted at SixthStreetPrivacy@sixthstreet.com.

Purposes and Legal Bases for Processing

We process your Personal Information for the purposes described above on the following legal bases, including:

·        As part of our legitimate interests to operate, manage and improve the Community and our business.

·        To comply with our legal obligations, including to prevent, investigate or provide notice of fraud, physical harm, financial loss, unlawful or criminal activity, or unauthorized access to or use of Personal Information, within the Community, and to enforce our Terms of Use.

We will also process your Personal Information when you have provided your consent for us to do so.

International Transfers

We seek to comply with applicable legal requirements providing adequate protection for the transfer of Personal Information to recipients in countries outside of the EEA, UK and Switzerland. In all such cases, we seek to only transfer your Personal Information if:

·        The country to which the Personal Information will be transferred has been granted an adequacy decision by the European Commission or UK Information Commissioner’s Office (as applicable); or

·        We have put in place other appropriate safeguards in respect of the transfer, for example by entering into the Standard Contractual Clauses.

You may request a copy of the safeguards that we have put in place in respect of transfers of Personal Information by contacting us as described in the “How to Contact Us About Privacy Matters” section below.

Your Data Protection Rights

1.      Rights Under Law of Various European Jurisdictions

If you are located in the EEA, UK or Switzerland, subject to applicable law, you may have the following rights in relation to Personal Information that we hold about you:

·        To request confirmation of whether we process Personal Information relating to you and, if so, to request a copy of that Personal Information;

·        To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;

·        To request that we erase your Personal Information in certain circumstances, such as where we collected Personal Information on the basis of your consent and you withdraw your consent;

·        To request that we restrict the use of your Personal Information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your Personal Information;

·        Where you have given us consent to process your Personal Information, to withdraw your consent;

·        To request that we provide a copy of your Personal Information to you or another organization in a structured, commonly used and machine readable format in certain circumstances; and

·        To object to certain of our data processing, such as for direct marketing purposes.

If you are located in the EEA, UK or Switzerland and you wish to exercise any of your data protection rights or if you consider that we have processed your Personal Information in violation of applicable law, please contact us as detailed in the “How to Contact Us About Privacy Matters” section below.

If you consider that we have processed your Personal Information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

2.      Rights Under California Law

If you are a resident of California, you may have rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, and implementing regulations (collectively, the “CCPA”) as described in this section of our Privacy Notice. Please note that nearly all of Personal Information we obtain, use and disclose is covered in whole or in part by applicable CCPA exemptions for financial data covered by federal law such as the Gramm-Leach-Bliley Act. We do not sell personal information subject to CCPA or disclose it for purposes of cross-context behavioral advertising, and have not done so within the past twelve (12) months.

Individuals who are California residents and whose information is covered by the relevant provisions of the CCPA, and is not subject to applicable exemptions, may have the following privacy rights, provided that the appropriate level of authentication is provided:

·        To request disclosure of Personal Information we collect and disclose about you during the 12-month period preceding our receipt of the request, including:

o   The categories of personal information we have collected about you.

o   The categories of sources from which we collected the Personal Information.

o   The business or commercial purposes for which we collected, disclosed, shared, or sold the Personal Information.

o   The categories of other parties with which we disclosed the Personal Information.

o   The categories of Personal Information that we have disclosed with other parties.

o   The specific pieces of personal information we collected.

·        To request deletion of your Personal Information.

·        To request correction of your Personal Information.

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 can be associated with a household (a group of people living together in a single home). 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 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.

You have a right not to be discriminated against for the exercise of the privacy rights conferred by the CCPA. If you exercise any of the rights explained in this Privacy Notice, we will continue to treat you fairly and not discriminate against you on the basis that you have exercised such rights.

You may exercise your rights by calling 1-877-543-3198 or contacting SixthStreetPrivacy@sixthstreet.com. We aim to provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.

To 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 consumer, we may request additional information from you and/or the consumer to verify their identity. 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.

How to Contact Us About Privacy Matters, and Updating Account Information

If you would like to contact us for any reason concerning our privacy practices or this Privacy Notice, please either email us at SixthStreetPrivacy@sixthstreet.com, or contact us at 1-877-543-3198. Alternatively, inquiries may be mailed to the following address:

Mailing address:

Sixth Street Partners c/o Legal and Compliance

888 Seventh Avenue, 41st Floor

New York, NY 10106

You may update and correct certain account information you provide to us at any time by logging into your account. If you wish to delete or deactivate your account, you may email us at ssp-mtccommunity@sixthstreet.com.

If you are based in certain jurisdictions, please also see your rights outlined above, including the right to delete and correct your personal information.

California Shine the Light

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to annually request, free of charge, information about the Personal Information (if any) disclosed to other parties for direct marketing purposes in the preceding calendar year. No information is disclosed with other parties for their own marketing purposes.

Information Related to Minors

Sixth Street does not knowingly collect information directly from minors—persons under the age of 16, or another age of a minor as defined by law—other than when required to comply with the law or for safety or security reasons.

If you are a parent or guardian of a minor who has provided information without your knowledge or consent, you may submit a request to remove the minor’s information by emailing us at SixthStreetPrivacy@sixthstreet.com.

Updates to This Privacy Notice

We may change or update portions of this Privacy Notice at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to the Privacy Notice. The revision date appearing on the first page of this Privacy Notice underneath the title will identify the date of the last update or revision.

Exceptions to This Privacy Notice

This Privacy Notice applies to the Community, and not broader areas of the Circle platform.  Please refer to Circle’s separate privacy notice for Personal Information that is collected for Circle’s purposes.