Change Forces, LLC, together with its affiliates and funds ("Change Forces", "us", "our" or "we"), have created this Privacy Policy to explain how we collect, use, store, share and transfer personal data and information ("Personal Data") we obtain through our website located at www.changeforcescap.com (the "Sites"), the Internet services that we offer (together with the Sites, the "Internet Services"), as well as through other means, as described below. Investors, employees, contractors and job applicants may receive a supplementary privacy notice and, in the event of any conflict with this Privacy Policy, the terms of such supplementary privacy notice will control.
When we use the term "Personal Data" in this Privacy Policy, we mean information relating to an identifiable individual person.
Where permitted by law, by using the Internet Services you consent to such use of your Personal Data and agree to the terms of this Privacy Policy.
Depending on where you are located and your interactions with the Internet Services, certain processing of your Personal Data by Change Forces may be subject to data protection and privacy laws, including the EU's General Data Protection Regulation (the "GDPR"), the UK Data Protection Act of 2018 along with the "UK GDPR" as retained as UK law by the European Union (Withdrawal) Act 2018 (together, the "UK GDPR"). and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"). For example, this may be the case where Change Forces processes the Personal Data of individuals in the EU and the UK who use the Internet Services (the "EU/UK Processing") or of users of the Sites who reside in California (the "CCPA Processing").
This Privacy Policy makes clear where its disclosures apply only to the EU/UK Processing or to the CCPA Processing. All other disclosures in this Privacy Policy relate to Personal Data to which the GDPR, the UK GDPR and the CCPA do not apply, as well as to the EU/UK Processing and the CCPA Processing.
This Privacy Policy was updated as of May 16, 2025.
Personal Data We Collect
We collect and use Personal Data in several ways, depending on how you interact with us. These include when you interact with us on our Sites and Internet Services, when you contact us by email, telephone or by other means, and when you visit one of our offices. If you provide Personal Data about any person other than yourself, you must ensure they understand how their Personal Data will be used and that they have given their permission for you to disclose the Personal Data to us and our outsourced service providers to use.
Information You Submit Through the Internet Services. When you interact with our Sites and other Internet Services, we may collect information you voluntarily provide to us, such as when you complete one of our online forms, join our mailing list or login to our investor portals. This information may include:
- Identifiers, such as your name, username and password, as well as contact details, such as your personal or work postal address, email address and phone number.
- Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, address and telephone number.
- Sensitive Personal Information such as your account log-in.
- Information about your communications with us, including the Personal Data you provide to us in email or in conversations with our employees and personnel; and
- Your marketing preferences, including any consents you have given us.
Information We Collect Automatically Through Our Internet Services.
We automatically collect certain Personal Data including internet and other electronic activity information to help us understand how you use the Internet Services (which we will refer to in this Privacy Policy collectively as "Usage Data"). For example, each time you visit the Sites, we may automatically collect your IP address, browser and computer or device type, access time, the webpage from which you came and the webpage(s) that you access during your visit. We may combine Usage Data with other Personal Data in a manner that enables us to trace Usage Data to an individual user. Some web browsers may have "do not track" settings. The Sites do not honor "do not track" settings.
Information We Collect from Third Parties.
On occasion, we may receive Personal Data from third party sources, such as where our trusted suppliers provide web analytics and reporting services to us.
Information We Collect When You Visit One of Our Offices.
When you visit one of our offices, we may collect Personal Data from you, including identifiers such as your name when you sign in at our front desk, and visual information collected through security cameras.
Sensitive Personal Information.
We may collect information that is considered "sensitive" under some laws including the CCPA, such as your account log-in if you log into our portal. When we do so, we use such information only for lawful purposes in compliance with the CCPA, GDPR and other applicable privacy laws, such as to perform the services or provide the goods requested by you and to resist malicious, deceptive, fraudulent or illegal actions. Where required by applicable law, we will obtain your consent prior to processing.
Cookies.
We may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer's hard drive) to keep track of your use of the Internet Services, to validate your identity, to remember your password and preferences, to tailor the Internet Services to your account and to meet your interests and to improve the quality of the Internet Services. Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain Internet Services may not function properly. We use Google Analytics to understand Site traffic. To learn more about the use of Cookies by Google for analytics and to exercise choice regarding those Cookies, please visit the Google Analytics Opt-out Browser Add-on.
Children.
We do not knowingly collect Personal Data from minors under the age of 16 nor do we target the Sites to minors.
Our Use of Personal Data.
The following table describes the purposes for which we process the Personal Data referred to above, and any information you give us, as well as the legal basis for the use of Personal Data that is subject to the EU/UK Processing.