Privacy Notice for California Residents
Last updated: February 2026
If you are a resident of the State of California, this Privacy Notice for California Residents (“California Notice”) may apply to you. This California Notice is intended to describe your rights under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”) and describes our data collection practices in more detail. Any terms defined in the CCPA have the same meaning when used in this California Notice.
If you are an employee residing in California, please refer to our California Employee Privacy Notice.
Collection of Personal Information
Through your interaction with us, we may collect the following categories and examples of personal information:
| Category | Examples of personal information we may collect |
| A. Identifiers. | A real name, alias, postal address, email address, Social Security number, driver’s license number, passport number, or other similar identifiers. Also may include references’ contact information (which the Consumer must obtain consent for before providing to us). |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, address, telephone number, insurance policy number, education, employment, employment history, as provided in an email, resume, cover letter or background check application. Some personal information included in this category may overlap with other categories. In rare cases, we may collect credit card and bank account information, as well as certain medical or heath information. |
| C. Protected classification characteristics under California or federal law. | Information about Consumer’s visa status and authorization to work in the relevant jurisdiction, demographic information including age and gender, and where applicable and in accordance with applicable law, veteran status. With Consumer’s permission or as permitted by applicable law, information obtained through background checks. |
| D. Commercial information. | Records regarding investment services and transactions. |
| E. Biometric information. | None. |
| F. Internet or other similar network activity. | Data related to a Consumer’s interaction with our Website. |
| G. Geolocation data. | Location of IP address, country/region of residence. |
| H. Sensory data. | Audio, electronic, visual, and similar information, such as images and audio, including CCTV footage of persons who enter our premises and recordings of calls during the job application process including interviews. |
| I. Professional or employment-related information. | Information related to one’s current or past job history (e.g., job titles, business name, performance details and contact information). |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, or student disciplinary records, as related to the application or recruitment process. |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, attitudes, intelligence, skills, abilities, interests and aptitudes as related to the application or recruitment process. |
| L. Sensitive Personal Information | In rare cases, we may collect social security, driver’s license, and passport numbers, as well as, where applicable and in accordance with applicable law, limited information about one’s religious beliefs, ethnic origin, and disability. |
| M. Communications | Information you email, submit or otherwise provide to us. This may contain personal information about you such as personal identifiers and professional or employment history. |
Categories of Sources from Which Personal Information is Collected
We collect personal information directly from you, from your communications with us, when you visit our offices or facilities, automatically via cookies and similar technologies, and from third parties, including government entities and service providers.
Business or Commercial Purposes for Collecting Personal Information
We use personal information for the business and commercial purposes disclosed under the “Purposes for Collecting Information” section of the Privacy Policy.
Disclosure of Personal Information
To appropriately interact with you, and to comply with applicable law, we may disclose your personal information to the parties described in the “How We Disclose Information” section of this Privacy Policy, including our affiliates, service providers, business partners and associates, and certain parties in connection with any actual or potential transfer or merger, sale, acquisition, assignment, transfer, or other disposition of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
Sale and Sharing of Personal Information
We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale” or “share” as that term is defined under the CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value, and “sharing” is broadly defined under the CCPA to include a disclosure for cross-context behavioral advertising. We may collect, share, or sell the following categories of personal information for commercial purposes: identifiers, characteristics, internet activity, non-precise geolocation data, and inferences drawn. The categories of third parties to whom we may sell or share your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising. We do not knowingly sell or share the personal information of minors under 16 years old who are California residents. For details on your rights regarding sales and shares, please see the CCPA Consumer Rights and How to Exercise Your Consumer Rights sections below.
Some of the personal information we collect may be considered sensitive information under the CCPA. For example, your driver’s license or passport number and your biometric information. We collect, use, and disclose such sensitive personal information only for the permissible business purposes for sensitive personal information under the CCPA or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.
Notice at Collection for Online Sources
The CCPA requires us to provide certain disclosures at or before our collection of personal information from California residents. The below Notice at Collection for Online Sources provides you with information about how we collect, use, and retain your personal information in the online context.
| Category of Personal Information | Purpose for Collection and Use | Is the Information Sold or Shared? | Criteria to Determine Retention Period |
| Identifiers |
|
Yes | We retain personal information as we determine is necessary for management of continuing contractual rights and obligations, compliance with applicable law, rule or regulation, the establishment, exercise or defense of legal rights or claims or protect our rights, respond to legal or regulatory requests or inquiries, which would include our need to comply with our contractual and other legal obligations, resolve disputes or claims, and enforce our agreements. We anticipate that this would continue for the period of your relationship with us, consistent with and proportional to our business record requirements. |
| Categories described in Civ. Code § 1798.80(e) | No | ||
| Professional or employment-related information. | No | ||
| Internet or other similar network activity | Yes | ||
| Non-precise Geolocation data | Yes | ||
| Inferences drawn from other personal information | Yes |
Sensitive Personal Information from Online Sources
Unless provided to us by you in a free text form, we do not knowingly collect Sensitive Personal Information, as defined by the CCPA, through online sources.
CCPA Consumer Rights
California residents may have certain consumer rights. These rights may include:
- The right to know what personal information we collect, including (1) the right to request information regarding the categories of personal information we collect along with other information such as the categories of sources from which the information is collected and third parties with whom it is shared and (2) the right to request a copy of the specific pieces of personal information we collect (sometimes referred to as the right to access personal information);
- The right to delete personal information that we collect from you, subject to certain exceptions;
- The right to correct inaccurate personal information that we maintain about you;
- The right to opt-out of the sale or sharing of personal information (as defined under the CCPA;
- The right to opt-out of certain uses of sensitive personal information; and
- The right not to be retaliated or discriminated against for exercising any CCPA rights in good faith.
How to Exercise Your Consumer Rights
If you wish to exercise any of the abovementioned consumer rights, you may call us at (212) 841-4100 or email your request to [email protected] with the phrase “California Consumer Rights” in the subject line.
You may also opt-out of sale or sharing of your personal information by us by turning on a recognized opt-out preference signal, such as Global Privacy Control, in your browser or extension. Please note that when you submit an opt-out through either method we do not know who you are within our systems, and your opt-out will apply only to information collected from tracking technologies on the specific browser from which you opt-out. If you delete or reset your cookies, or use a different browser or device, you will need to reconfigure your settings.
Before we can honor any such request, we need to verify that the request is really made by you. In order for us to verify that any such request is being made by you, we will need you to provide us with your full legal name and email address that matches the information in our records. In addition, if you have a current relationship with us, we may contact you and ask you to provide other additional information about you or your request.
Additional Privacy Notices
If you are an investor in a Millennium Fund, also see the privacy notice on the Investor Portal.
Changes to this Privacy Policy
We reserve the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of our Website and/or Services by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to our Website. We will notify you of significant changes or updates to our Privacy Policy by additional means, such as posting a notice on the front page of our Website and/or sending you an e-mail.
Contact Us
If you have any questions about this Privacy Policy, or our privacy related practices, you can contact us at [email protected].