Notices and Disclaimers
Statements of notices, disclaimers and regulatory disclosures.
Please be aware that Carlyle’s name, brand, and reputation may periodically be misused by unauthorized persons to publish fake news articles and websites; launch illegitimate marketing, fundraising, and/or investment campaigns; or engage in other fraudulent schemes, such as illicit recruitment activities, to gain money and/or confidential information as well as to deceive, misinform, or otherwise cause harm to individuals and businesses. The actions of these unauthorized persons are not associated with Carlyle and, as such, Carlyle is not responsible for the consequences of any of these fraudulent activities.
Please be informed that The Carlyle Group does not authorize any misuse of its name, brand, or reputation, and does not tolerate fraudulent activity. The Carlyle Group does not and will not conduct any solicitation to the public with respect to investments, fundraising, or opening accounts, including print and online articles, advertisements, or postings on social media sites, messaging apps, such as Telegram, WeChat, or WhatsApp, or other public platforms. Carlyle reserves the right to take all appropriate steps to protect its legal rights and reputation.
When communicating with Carlyle through digital media, please:
- Be cautious about responding to unsolicited emails that appear to have come from a Carlyle email address. Such emails may be “spoofed,” and may in fact have come from another email address at another domain name. Check email addresses carefully and respond only to known or authorized Carlyle email accounts at the domain names listed below.
- Be cautious about clicking on links or opening attachments included with unsolicited emails that appear to have come from a Carlyle email address. These links may redirect to a non-Carlyle site, and these attachments may include malware.
- Do not send emails intended for Carlyle employees or representatives to anyone with an email address other than an authorized Carlyle email address. Carlyle does not permit our employees and authorized representatives to send or receive work-related emails from personal webmail accounts or any other addresses.
- Communicate only with Carlyle’s authorized website and email domains listed below. No other website domains are authorized.
- carlyle.com (Carlyle’s official global website)
- carlyle.com/zh-hans (Carlyle’s official Chinese website)
- carlyle.com/ja (Carlyle’s official Japanese website)
- alpinvest.com (Global Investment Solutions)
- carlyle.aero (Carlyle Aviation Partners)
- carlylesecuredlending.com (Carlyle Secured Lending)
- Review the information posted in the “Offices” section of “Contact Us” for a listing of authorized Carlyle locations.
If you have any questions about the above and/or would like to make us aware of any suspected unauthorized activity involving Carlyle, please contact us at email@example.com.
“Carlyle” and “凯雷” are registered trademarks of TC Group, L.L.C.
On May 14, 2009, Carlyle became a signatory to the Public Pension Fund Code of Conduct (the "Code"). Please click here for annual certifications.
Pursuant to the Code, Carlyle is providing information regarding the professional backgrounds of certain key Carlyle personnel (“Disclosure Persons”) and such information can be found under their individual biographies in the “Team” section of this website, or by clicking Disclosure Persons.
Also pursuant to the Code, Carlyle is disclosing certain fees and expenses that have been paid on an aggregate basis with respect to investment funds to which U.S. public pension funds have committed and the form of disclosure provided to public pension funds in respect of their investment:
Carlyle is a member of the Bundesverband Deutscher Kapitalbeteiligungesellschaften (BVK), the German private equity and venture capital trade association. Carlyle believes that it is fully compliant with the voluntary BVK Guidelines for Disclosure and Transparency and that our German portfolio companies, including HC Starck and the Puccini Group, will comply with the BVK Guidelines as and when the guidelines apply to them. Click here to read more.
In the UK Carlyle voluntarily complies with the Private Equity Reporting Group (PERG) Guidelines for Disclosure and Transparency in Private Equity. Carlyle’s disclosure can be found here: PERG Disclosure
Also in the UK, pursuant to the Modern Slavery Act 2015, CECP Advisors LLP and CELF Advisors LLP make statements setting out steps that we have taken to seek to ensure that modern slavery and human trafficking are not taking place in our business and supply chains. Each of the statements can be found here:
Pursuant to the EU Sustainable Finance Disclosure Regulation (2019/2088) (“SFDR”), CIM Europe S.à r.l. and Carlyle Real Estate Società di Gestione del Risparmio S.p.A. respectively make the following disclosures in accordance with Articles 3(1), 4(1)(b) and 5(1):
- CIM Europe – SFDR Disclosure Articles 3(1), 4(1)(b) and 5(1)
- Carlyle Real Estate SGR – SFDR Disclosure Articles 3(1), 4(1)(b) and 5(1)
Global / UK Tax Strategy
Carlyle is committed to compliance with all statutory obligations and full disclosure to tax authorities. Our tax affairs are managed and in alignment with Carlyle’s overall approach to corporate reputation and our high standards of governance and transparency. Click here for more information about how we manage our tax affairs.
Carlyle’s affiliated entity, TCG Gestor Ltda., is subject to the regulation of the Brazilian Securities Commission ("CVM"), including, but not restricted to CVM Rule 558, which regulates asset management activities in Brazil. Among other things, CVM Rule 558, requires TCG Gestor Ltda. to post on its website its Disclosure Documents and certain policies required by applicable by law. Below are links to the required documents in Portuguese.
The information contained in this website is for informational purposes only and do not constitute offering of any product. TCG Gestor Ltda. does not sell or distribute investment fund units or any other financial assets. The funds managed by TCG Gestor Ltda. are distributed by institutions duly authorized by both the Brazilian Central Bank (BACEN) and the Brazilian Securities Commission (CVM) for the exercise of such activity. READ THE FUNDS BY-LAWS AND PROSPECTUSES CAREFULLY BEFORE INVESTING IN THE FUNDS MANAGED BY TCG GESTOR LTDA.
A TCG Gestor Ltda. é uma entidade filiada ao Carlyle sujeita à regulação da Comissão de Valores Mobiliários (“CVM”), incluindo, mas não se limitando à Instrução CVM n.º 558, que regula as atividades de gestão de recursos no Brasil. Além de outros requisitos, a Instrução CVM n.º 558 exige que a TCG Gestor Ltda. publique em seu website o seu Formulário de Referência e determinadas políticas exigidas pela regulamentação aplicável. Abaixo estão os links dos documentos em português.
- TCG Gestor - Formulário de Referência
- TCG Gestor - Código de Ética e Conduta
- TCG Gestor - Política de Prevenção e Combate à Lavagem de Dinheiro
- TCG Gestor - Política de Continuidade dos Negócios
- TCG Gestor - Política de Gestão de Riscos
- TCG Gestor - Política de Negociação Pessoal
- TCG Gestor - Segurança da Informacão e Segurança Cibernética
As informações contidas neste website são de caráter exclusivamente informativo e não configuram oferta de qualquer produto. A TCG Gestor Ltda. não comercializa nem distribui cotas de fundos de investimento ou qualquer outro ativo financeiro. Os fundos geridos pela TCG Gestor Ltda. são distribuídos por instituições devidamente habilitadas e autorizadas pelo Banco Central do Brasil e pela CVM para o exercício de tal atividade. LEIA O PROSPECTO E O REGULAMENTO ANTES DE INVESTIR NOS FUNDOS GERIDOS PELA TCG GESTOR LTDA.
Pursuant to the Financial Instruments and Exchange Law of Japan, effective as of March 1, 2016, a person who has submitted a notification regarding Specially Permitted Businesses for Qualified Institutional Investors, etc. is required to make available to the public certain information. Information on the following entities can be obtained upon request:
- TC Group VI, L.L.C.
- TC Group VI-F, L.L.C.
- TC Group VII, L.P.
- TC Group VIII, L.P.
- CP Growth GP, L.P.
- CGP II, L.L.C.
- CCCDSF General Partner, L.P.
- Carlyle Japan II Ltd
- Carlyle Japan III, Ltd
- Carlyle Japan IV, L.L.C.
- CJP III Japan ILP GP, Ltd.
- CJP IV Japan ILP GP, Ltd.
- CAP IV, L.L.C.
- CAP V, L.L.C.
- CAP VI, L.L.C.
- CAP Growth II, L.L.C.
- CEP V Holdings, L.L.C.
- CEP VI Holdings, L.L.C.
- CETP V Holdings, L.L.C.
- Carlyle Property Investors GP, L.L.C.
- CERF II Managing GP Holdings, L.L.C.
- Carlyle Diversified Infrastructure GP, L.L.C.
- CRSEF II GP, L.L.C.
- Carlyle Realty X, L.L.C.
- CICF General Partner, L.P.
- Carlyle Direct Lending Fund IV GP, L.L.C.
- CDL Offshore IV GP, L.L.C.
- CDL Treaty IV General Partner, S.à r.l.
- CDL 2023-1 GP Ltd.
- CCOF III General Partner, L.P.
- CCOF III Plus General Partner, L.P.
If you would like to obtain information, please send an email to CarlyleAsia.FIELFilings@carlyle.com
Updated August 10, 2022
The Carlyle Group’s commitment to privacy
This Privacy Notice is provided by The Carlyle Group (“Carlyle”, “we” and “us”). For administrative convenience purposes only and not as a result of regulatory requirements, this Privacy Notice also applies to Carlyle’s affiliates (please see Annex A below for a schedule of certain entities that may act as a data controller with respect to personal data), as the technology platform used by these entities operates on an integrated basis. At a high level, this Privacy Notice applies to ways in which we interact with individuals, (“Data Subjects”) in connection with our business, including, without limitation:
- directors, officers, employees and other representatives of portfolio companies in which Carlyle has made an investment or is considering making an investment;
- individual representatives of third-party sellers, placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and other service providers, whether or not engaged by Carlyle;
- directors, officers, employees and other representatives of Carlyle;
- individuals applying for or enquiring about and employment with us;
- individuals who consider or do invest with us and their representative agents with whom we interact during the normal course of business; and
- visitors to our websites and users of any digital services we provide.
We respect the privacy of Data Subjects. This Privacy Notice describes how Carlyle entities will generally collect, use, store, process, disclose and transfer information that each may collect from Data Subjects. Please note that we may provide additional privacy notices or similar disclosures in respect of certain entities within Carlyle, categories of Data Subjects (e.g., certain investors or prospective investors in a fund managed or advised by Carlyle, certain former or existing employees associated with Carlyle, etc.), and certain geographies and jurisdictions.
What data do we collect and how?
Personal Data. When we use the term “Personal Data” we mean information that reasonably can be used to identify you as an individual person. In connection with our business, we collect various types of Personal Data, including, among other things:
- Identifiers such as your name, postal address, tax ID, passport number, internet protocol address, email address, account name, social security number, driver’s license number, mail address, phone number, or other similar identifiers.
- Information classified as personal or protected information by state, federal, or other applicable law, including your nationality, place and date of birth, gender, picture, marital status, number of children, and information on criminal history/unlawful conduct.
- Commercial information, including tax information, bank account details, credit card number, money transfers including communications on bank transfers, assets, investor profile, credit history, debts and expenses.
- Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Visual information, including your picture.
- Professional or employment-related information, including your employment, employer’s name, and remuneration.
- Education information, including your level of education.
We collect this Personal Data in various ways, including:
- Directly from the Data Subject (e.g., when you voluntarily submit information to the Site, or send us an email or other written correspondence).
- Indirectly from other sources (e.g., from public records or from a counterparty in possession of the data).
If you are located outside of the United States, please be aware that the Personal Data we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen. We will ensure appropriate safeguards are in place to adequately protect your Personal Data, as required by applicable law.
How and on what basis do we use your Personal Data?
We use your Personal Data for a variety of reasonable and legitimate business purposes, including, but not limited to, the following:
- Complying with legal or regulatory obligations, such as our obligations regarding know-your-client and anti-money laundering due diligence;
- Performing a contract with you or to take steps at your request before entering into a contract, including to: (i) provide you with information regarding Carlyle products or services; (ii) assist you and answer your requests; (iii) evaluate whether we can offer you a Carlyle product or service and under what conditions; and (iv) responding to know-your-client and anti-money laundering information requests presented by counterparties with whom we do business on your behalf or for your benefit; and
- Other legitimate purposes, such as:
- Communicating with Data Subjects;
- Performing activities relating to client management, financial management and administration;
- Creating, improving and developing our products and services;
- Conducting market research, surveys, and similar inquiries to help us understand trends, client and Site visitor needs;
- Monitoring and auditing compliance with internal policies and procedures, legal obligations and to meet requirements and orders of regulatory authorities; and
- Processing and considering applications for employment, including evaluating and confirming your suitability for the position and accuracy of any information submitted.
- Communicating with Data Subjects;
We will not use your Personal Data for any purposes inconsistent with this Privacy Notice without your permission.
We do not sell any personal data and have not sold any personal data in the past.
With whom do we share your Personal Data?
Within Carlyle. We share your Personal Data among Carlyle entities and affiliates for the purposes set forth above. In general, our group entities, in turn, are not permitted to share your information with other non-affiliates entities, except as described herein or otherwise permitted by applicable laws.
To Third Parties. We share your Personal Data with third parties in certain circumstances, including the following:
- Service Providers. We share Personal Data with service providers that perform services on our behalf (e.g., third-party service providers to operate a Site) and with service providers and other counterparties to our clients and investors. These companies may have access to your Personal Data but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. We generally require these providers by contract to keep the information confidential.
- Transaction or Other Corporate Event. Your Personal Data can be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, financing or sale of company assets, including bankruptcy proceedings, or other investment activity, and could be transferred to a third party as one of the business assets in such a transaction. It also can be disclosed in the event of insolvency, bankruptcy or receivership. In such an event, we will post prominent notice of the change in ownership.
- As Required by Law. We also disclose your Personal Data if we are required to make disclosures by applicable law or to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or as part of our legislative or regulatory reporting requirements.
How do we protect your Personal Data?
We take seriously the obligation to safeguard your Personal Data. Your Personal Data held by us will be kept confidential in accordance with applicable Carlyle policies and procedures. We will use all reasonable efforts to ensure that all Personal Data is kept secure and safe from any loss or unauthorized disclosure or use. All reasonable efforts are made to ensure that any Personal Data held by us are stored in a secure and safe place and accessed only by our authorized employees and transferees.
Keeping your Personal Data current
In general, we seek to ensure that we keep your Personal Data accurate and up to date. However, you are responsible for, and we kindly request that you inform us of, any changes to your Personal Data (such as a change in your contact details). To update or edit your Personal Data that we have on file, including your communication preferences, please contact us using the contact details set out under the “Contact and Complaints” heading below or by sending an e-mail to firstname.lastname@example.org.
How long do we keep your Personal Data?
In general, we will process and store your Personal Data for at least as long as it is necessary in order to fulfil our contractual, regulatory and statutory obligations, which may differ depending on the relevant Group entity or jurisdiction. Subject to those qualifications, our goal is to keep such data for no longer than necessary in relation to the purposes for which we collect and use the Personal Data (we refer to the purposes as set forth above). Carlyle will retain your Personal Data in accordance with our Books & Records Policy. If you have any specific questions in this respect, please feel free to contact us.
Contact and Complaints
Carlyle takes very seriously any complaints we receive about our use of your Personal Data. Questions, comments, requests or complaints regarding the Site, this Privacy Notice, the User Agreement and/or our use of your Personal Data should be addressed to email@example.com.
Should your query concern AlpInvest Partners B.V. you may lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, www.autoriteitpersoonsgegevens.nl/en), or for other European entities with the relevant local Data Protection Authority.
Any Personal Data we receive from you when making a complaint will be treated in accordance with this Privacy Notice and only to process the complaint and check on the level of service we provide. Similarly, where inquiries are submitted to us we will only use the information supplied to us to deal with the inquiry and any subsequent issues and to check on the level of service we provide.
Our websites are operated from servers in the United States and include:
BY USING OUR WEBSITES AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL DATA IN THE UNITED STATES.
Please be aware that a Site may contain links to other websites hosted by third parties. The Carlyle Group does not control and is not responsible for the content or privacy practices and policies of such third-party websites. We encourage you to be aware when you leave a Site and to read the privacy policies of each third-party website, especially if such website collects Personal Data from you.
Additional Information for Job Applicants to the Carlyle Group and AlpInvest
The Carlyle Group Applicant Privacy Notice pertains to all individuals applying to become employees or members associated with Carlyle. Questions, comments, requests or complaints regarding this Privacy Notice and/or our use of your Personal Data should be addressed to firstname.lastname@example.org.
Additional Information for Residents of the European Economic Area (the “EEA”) and the United Kingdom (the “UK”)
The below information applies to any Data Subject resident in the EEA or the UK. For purposes of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 and the UK Data Protection Act 2018 (both referred to herein as the “GDPR”):
The applicable data controllers for the Sites will be:
- The Carlyle Group whose headquarters is located in the United States at 1001 Pennsylvania Avenue, NW, Washington, DC 20004.
- AlpInvest Partners B.V. with its registered office at the Jachthavenweg 118 in (1081 KJ) Amsterdam, the Netherlands. AlpInvest is registered with the trade register of the chamber of commerce under company number 27186537.
The data controller is responsible for deciding how we hold and use Personal Data about you.
GDPR Data Protection Principles
In respect of the collection, holding, storage, use, and processing of your Personal Data:
- We will process the data lawfully, fairly and in a transparent way.
- We will obtain the data only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- The data we collect will be relevant to the purposes we have told you about and limited only to those purposes.
- We will take reasonable steps to ensure that the data is accurate and kept up to date.
- Subject to applicable legal or other requirements, we will keep the data only as long as necessary.
- We will use appropriate technical and/or organizational measures to ensure appropriate security of the data.
Transfer of Personal Data Outside of the UK/EEA
The transfer of Personal Data from the UK/EEA to the Carlyle entities outside the UK/EEA is governed by data transfer agreements which are in the form of the standard contractual clauses approved by the European Commission (a copy of which can be obtained from us via the contact details below).
Where your Personal Data is processed by third parties outside the UK/EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including the execution of standard contractual clauses (referred to above) if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission).
GDPR Data Subject Rights
Under the GDPR, in certain circumstances, an EEA-resident Data Subject has certain individual rights with respect to the Personal Data that we hold about them. In particular, you may have the right to:
- Request access to any data held about you
- Ask to have inaccurate data amended
- Request data held about you to be deleted, provided the data is not required by Carlyle to perform a contract, defend a legal claim or to comply with applicable laws or regulations
- Prevent or restrict processing of data which is no longer required
- Request transfer of appropriate data to a third party where this is technically feasible
Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
To exercise any of these rights, please contact us using the contact details set out under the “Contact and Complaints” heading above.
Automated Decision Making
We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Data, including profiling, especially where such processing has legal or other significant effects on you. In establishing and carrying out a business relationship, we generally do not use any automated decision making pursuant to the GDPR. We may process some of your Personal Data automatically, with the goal of assessing certain personal aspects (profiling), such as to comply with legal or regulatory obligations to combat money laundering, terrorism financing, and offenses that pose a danger to assets. We also use assessment tools in order to be able to allow communications and marketing to be tailored as needed.
Complaints to Local Authorities
As a resident of the EEA or UK, you are also entitled to direct any complaints in relation to our processing of your Personal Data to your national or local data protection supervisory authority.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
California Data Subject Rights
California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what Personal Information is disclosed to third parties for direct marketing purposes in the preceding calendar year. For more information on these disclosures, please contact us using the contact details set out under the “Contact and Complaints” heading above.
In addition, Data Subjects in California may have a right under the California Consumer Privacy Act (“CCPA”) to request erasure of their personal data or access to personal data that we have collected in the last twelve (12) months.
You may submit requests for access or erasure of your personal information by calling (855) 283-9736 or contacting us at email@example.com.
Individuals who submit requests for access or erasure of personal information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until identity is verified.
If you are making a request for access, we may not be able to provide specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your personal information, your account with us, or our systems or networks.
If you are making a request for erasure, we will ask that you confirm that you would like us to delete your personal information again before your request is addressed.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents who make requests on behalf of individuals, will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.
Under the CCPA, you cannot be discriminated against for exercising your rights to access or request erasure of their personal data.
China Data Subject Rights
With respect to Personal Data of Data Subjects in China, we will comply with the applicable obligations and requirements in the Personal Information Protection Law of China (the “PIPL”) when providing that data to other parties or transferring that data outside of China. Please refer to Annex B for more details on processing and cross-border transfer of Personal Data of Data Subjects in China.
Below are country-specific contact details for certain relevant local entities that may be deemed “controllers” with respect to applicable personal data.
|China||Carlyle Investment Consulting (Shanghai) Co., Ltd.
(including its Beijing branch)
Unit 4001, 40th Floor, Tower 2
|China||Carlyle (Beijing) Investment Management Co., Ltd.||Unit 1918, Level 19
China World Tower A
No. 1 Jianguomenwai Avenue
Beijing 100004 China
|China||Carlyle-Fosun (Shanghai) Equity Investment & Management Co., Ltd.||Unit 4001, 40th Floor, Tower 2
Jing An Kerry Centre
1539 Nanjing Road West
Shanghai 200040, China
|France||Carlyle Real Estate Advisors S.a.r.l.||112 avenue Kléber
|France||CECP Investment Advisors France S.A.R.L.||112 avenue Kléber
|Germany||CREA Germany GmbH||Promenadenplatz 8, 80333
|Italy||Carlyle Real Estate Società di Gestione del Risparmio S.p.A.||Piazza Cavour 2
|Italy||CEP Advisors, S.r.l.||Piazza Cavour 2
|Luxembourg||CIM Europe S.àr.l.||2, avenue Charles de Gaulle
|Netherlands||AlpInvest Partners B.V.||Jachthavenweg 118
1081 KJ, Amsterdam
|Spain||The Carlyle Group España, SL||Pau Casals, 13
|United Kingdom||Carlyle Real Estate Advisors LLP||1 St James's Market
|United Kingdom||Carlyle Real Estate Advisors UK Limited||1 St James's Market
|United Kingdom||CECP Advisors LLP||1 St James's Market
|United Kingdom||CELF Advisors LLP||1 St James's Market
|United Kingdom||AlpInvest Partners LLP||1 St James's Market
This Annex applies to Data Subjects in China in addition to the provisions in the foregoing Privacy Notice. In case of discrepancies between this Annex and the Privacy Notice, the more restrictive requirements shall apply.
- Name and contact details of the handlers of Personal Data
Depending on which Carlyle entity you are employed by, one or more of the following entities in China will be the “handler(s)” of your Personal Data for the purpose of Chinese laws including the PIPL.
Name Contact Details Carlyle Investment Consulting (Shanghai) Co., Ltd. (including its Beijing branch) firstname.lastname@example.org Carlyle (Beijing) Investment Management Co., Ltd. email@example.com Carlyle-Fosun (Shanghai) Equity Investment & Management Co., Ltd. firstname.lastname@example.org
Types of Personal Data collected and processed
Personal Data means all kinds of information recorded in electronic of other form relating to an identified or identifiable natural person. Please refer to the section titled “What Personal Data do we collect and how?” in the Privacy Notice for the types of Personal Data that the handler(s) collect and process relating to you.
Some Personal Data collected and processed by the handler(s) are considered as “sensitive personal information” (as defined under the PIPL), for example information on financial accounts etc.
Purposes, methods of processing
The handler(s) may collect, store, use, refine, transfer, provide, disclose and delete your Personal Data as described and for purposes identified in the section titled “How and on what basis do we use your Personal Data?” in the Privacy Notice.
We keep Personal Data for no longer than necessary in relation to the purposes for which we collect and use the Personal Data. After the relevant purposes are realized, we will either (a) delete the Personal Data or (b) stop all processing activities in connection with the Personal Data (except for storing the same and necessary security measures), if deletion is technically unfeasible or we are legally required to keep those data longer.
Provision, transfer, and disclosure of Personal Data
This website is hosted on servers in the United States. When you submit a request, make an inquiry or otherwise interact with us via this website, your personal information will be transmitted to Carlyle and stored on its servers in the United States.
In addition, as part of Carlyle, a business operating globally, the handler(s) need to provide and transfer your Personal Data to the “Recipient(s)” in the table below. The types of Personal Data processed by these Recipients and the purposes and methods of their processing activities are the same as described in 2 and 3 above.
Necessity of processing Sensitive Personal Data and its impact
We collect and process sensitive Personal Data in strict compliance with the law and only when necessary for specific and legitimate purposes. Such purposes include complying with anti-money laundering and terrorism financing laws, conducting “know-your-client” checks, providing you with personalized services, protecting your vital interests in emergency, for reasons of public health, or other legitimate purposes referred to in 2 above.
Name Location Contact Details Carlyle Investment Management L.L.C. United States c/o The Carlyle Group
1001 Pennsylvania Avenue, N.W.
Suite 220 South
Washington, DC 20004
We have adopted strict measures to protect your Personal Data, especially sensitive Personal Data. Failure to provide us with the relevant information may prohibit you from accessing to some services we provide, or negatively affect our ability to respond to your requests. If you have questions in this regard or wish to have more detailed information on any specific issue, you may contact us via the methods below.
Exercise of Rights
If you have any issues, queries or complaints regarding the processing of your Personal Data or wish to exercise your rights in relation to your Personal Data with Carlyle or the Recipient(s), please send an email to email@example.com for further information or for submitting your requests.
We may request information from you in order to verify your identity or understand your request as well as to ensure that you are entitled to make that request under the law. We will respond to your request in a timely manner (generally within 30 days).
Updated February 2023
This Privacy Notice (“Privacy Notice”) is provided by The Carlyle Group, Inc., and its subsidiaries including AlpInvest and describes how we and our subsidiaries, affiliates and related entities (collectively “we”, “our”, “us”) collect and process personal data about you during the application and recruitment process. This Privacy Notice applies to job applicants and prospective job applicants only, and is supplemental to our website privacy notice, which can be found at https://www.carlyle.com/notices-and-disclaimers#privacy-notice. To the extent terms of this notice and our website privacy notice conflict, this notice supplants our website privacy notice.
This Privacy Notice also applies to personal data collected throughout the recruitment and application process, including data uploaded to third-party other online job applicant tracking system or platform we use, such as Avature (the “Job Portal”). It does not apply to other websites or pages that we own or operate.
For the purposes of this Privacy Notice, “personal data” means any information that relates to an identified or identifiable individual, and may in certain countries include opinions about that individual, whether or not the opinion is true or recorded in a material form. Depending on the country in which you live or work, you may know or refer to personal data as “personal information”, “personally identifiable information”, “PII” or other similar terms. This Privacy Notice does not apply to anonymous, de-identified or non-identifiable data or information that alone or in conjunction with other information we could reasonably access is not associated with a particular individual.
Depending on where you are located or the entity to which you apply, our processing of your personal data may be subject to various applicable privacy and data protection laws. In our use of your personal data, we are characterized as a “data controller”, a “controller”, a “business”, an “accountable entity” or an “organization” for the purposes of some or all of these laws. The data controller, business, accountable entity or organization applicable to you is the Carlyle or AlpInvest entity to which you are applying.
Please be aware that any relevant misrepresentation or false statements you make in your application or during the recruitment process may, as permitted by applicable law, be sufficient cause for: (1) disqualification from consideration for employment with us; or (2) discipline up to and including termination from employment should the relevant misrepresentation or false statements affect the basis of the employment relationship with us.
WHAT PERSONAL DATA WE HOLD ABOUT YOU
In connection with your application for employment with us and the recruitment process, we will collect, store, share, and use personal data about you, including inferences drawn from this personal data. We may process some or all of the following categories of your personal data when applicable to your application or provided by you ategorized:
- Identifiers such as your name, title, gender, race, ethnicity, sexual orientation, date of birth, birth city and country, marital status, dependents, postal address, telephone number, personal email address, current work contact details and any emergency contact details you provide.
- Professional or employment-related information including your current employer and employment history and other relevant experience including information contained in your resume, CV, cover letter and/or job application.
- Education information including degrees and grades awarded, transcripts, licences, registrations, certificates, language skills and other information provided in support of the job application.
- Your identification documents including your passport, government identification, residency, visa type and immigration status.
- Information collected during interviews, assessments, screenings and otherwise during the application process, including phone and video calls and other correspondence, and details for pass cards and CCTV imaging recording information.
- Details regarding the type of employment and job function sought, desired salary, contractual details, willingness to relocate, job preferences and other information related to compensation and benefits.
- Reference information and information received from background checks (including criminal record checks), where applicable, including information provided by third parties.
- Information required for regulatory or compliance purposes, such as information relating to outside business activities, personal account dealing, and past political contributions and other involvement with public officials or candidates for public office.
- Information related to previous applications to or previous employment history with us.
- Communication and calendar information (such as e-mails sent to candidates).
- Internet or other electronic network activity information such as your computer IP address, device identifiers, the type of operating system and browser type you are using and standard web log data.
The laws in your country of your residence or that apply to our processing of your personal data may distinguish between personal data and “special categories” of personal data that may require a higher level of protection. In exceptional cases, we may collect, store and use the personal data, including inferences drawn from this personal data, that are categorized as “sensitive” or “special” by certain applicable privacy and data protection laws. The sensitive personal data we process includes some or all of the following categories where they are applicable to your application and to the extent that they are categorized as sensitive personal data by, or otherwise subject to, applicable data protection laws:
- Criminal charges, convictions and other offences information, including disciplinary actions taken by regulatory authorities, and other background checks (where permitted by applicable law) and screening information.
- Health information such as illness and accidents information, health, pandemic viral related testing (such as thermal and symptom screening, temperature checks and medical attestations), symptom tracking and contact tracing information, data on sick leave and disability information.
- Trade union membership information, passport number and issue information, and government and national identification information.
- Financial information such as banking data, wage tax class and other wage tax details, employer and employee social security contributions, salary and compensation information, service gratuity and other allowances, long-term incentive plan details, third party payments, and private investments and trading activities information.
- Biological, physical and cultural characteristics information such as ethnicity and/or race information.
- Religious, political and philosophical information such as religious, spiritual, philosophical or political beliefs, practices and traditions information.
- Technological information such as about IP addresses, internet login information (such as websites visited, applications downloaded), passwords, CCTV imaging recordings and information regarding communications sent or received via systems (for example, email and voice recordings).
HOW WE COLLECT YOUR PERSONAL DATA
We collect personal data about candidates from the following sources:
- Directly from you, the candidate (such as when you voluntarily submit an application to the Job Portal or send us an email or other written correspondence).
- Indirectly from other sources (for example, recruitment and employment agencies, reference check providers, your named referees, government agencies, certification bodies, publicly accessible sources, such as social media platforms, and other third parties as required or permitted by law).
Please ensure you have the consent of any referee whose details you provide alongside your application for us to use their personal data as outlined in this Privacy Notice. If you provide us with personal data about members of your family and/or dependents or beneficiaries, it is your responsibility to inform them of their rights with respect to such personal data. You also are responsible for obtaining the explicit consent of these individuals (unless you can provide such consent on their behalf) to the processing (including the transfer) of that personal data for the purposes set out in this Privacy Notice.
You may be requested to provide some or all of the personal data described in this Privacy Notice as part of the application and recruitment process. If you fail to provide the personal data when requested, and this personal data is necessary for us to consider your application (such as evidence of qualifications or work history) or otherwise to comply with our legal or contractual obligations, we will not be able to process your application or continue the recruitment process. In all other cases, the provision of your personal data is voluntary.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data where we have a justifiable purpose or purposes for doing so or the law otherwise allows or requires us to, unless we reasonably consider that we need to use the data for another reason and that reason is compatible with the original purpose. Where required by applicable law, we will not use or otherwise process your personal data for a secondary or unrelated purpose without first obtaining your consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
We will use the personal data we collect about you for the following purposes including and to the extent that such purposes are required or permitted by applicable law:
- Where necessary for us to review and assess your application for employment in order to enter into an employment relationship with you
This includes assessing your skills, qualifications and suitability for the role; processing your application; analyzing your qualifications; verifying your identity and carrying out background and reference checks, where applicable; and communicating with you about the recruitment process.
- Where necessary for our legitimate business interests and, to the extent required or permitted by applicable law, where these interests are not overridden by your applicable rights and freedoms (including your applicable data protection rights)
This includes deciding whether to employ you in a specific role that would be beneficial to our business; keeping records related to our hiring processes; where permitted, for the purposes of “talent pooling” and contacting you about opportunities that may arise in future; protecting our legal rights; maintaining the security and integrity of our facilities, equipment and electronic platforms; maintaining information on the business and technical environment in which we operate; monitoring compliance with our protocols and policies; and taking reasonably necessary steps to ensure that we have appropriate and effective health screening measure in place.
- To comply with legal or regulatory requirements
This includes fulfilling our legal obligations to conduct background, screening and eligibility to work checks, where applicable; making disclosures to law enforcement agencies or in connection with legal or regulatory claims, allegations or requests, including the disclosure of personal data in connection with legal processes and litigation; and providing a safe working environment for our employees and other individuals who visit our premises.
- Where necessary for the performance of a task carried out in the public interest or to protect your interests (or someone else’s interests)
This includes conducting pandemic viral-related testing (such as thermal and symptom screening, temperature checks and medical attestations), symptom tracking and contact tracing (location) information (including any personal/business related travel location and quarantine information).
- Where you have given consent
Where required or permitted by applicable law, we may ask you for your consent to carry out certain processing activities, including verification and background checks, or as otherwise required by applicable law, where this is required in connection with your role. Where we process personal data based on your consent, you can withdraw your consent at any time where this is permitted by applicable law.
We respect your legal rights not to be subject to decisions that are based solely on automated processing of your personal data, including profiling, especially where such processing has legal or other significant effects on you.
We inform our applicants about any such automated decisions. Subject to certain exceptions, we usually obtain the relevant individual’s explicit consent before making any decisions based solely on automated processing activities and put in place appropriate safeguards to protect their rights, freedoms and legitimate interests in these circumstances.
We will not make any automated decisions based on sensitive personal data unless we have obtained explicit consent from individuals to do so, or this is otherwise necessary for substantial public interest reasons based on applicable law.
HOW WE WILL USE SENSITIVE PERSONAL DATA
We collect, process and otherwise use your sensitive personal data for the following specific purposes, including and to the extent that such purposes are required or permitted by applicable law:
- Where necessary for the purposes of carrying out obligations in the field of employment, social security and social protection law
This includes facilitating effective equal opportunities monitoring and reporting and to comply with obligations regarding diversity; complying with legal obligations to make reasonable adjustments and accommodations (for example, when you undertake assessments or attend an interview); obtaining a Good Conduct Certificate for the purpose of securing an employment resident visa as required in certain countries; and providing a safe working environment for our employees and other individuals who visit our premises.
- Where necessary for reasons of substantial public interest
This includes conducting pandemic viral-related testing (such as thermal and symptom screening, temperature checks and medical attestations), symptom tracking and contact tracing (location) information (including any personal/business related travel location and quarantine information).
- Where necessary to protect your vital interests where you are physically or legally incapable of giving consent
This includes providing personal data to medical advisers if you were to fall seriously ill during a visit to our premises. This legal basis for processing is only relied upon in “life or death” type situations.
- Where you have given consent
Where required by applicable law, we may ask you for your consent to carry out certain processing activities, including verification, background or criminal records checks, or to use your sensitive personal data where we do not have another legal basis to do so (for example, to share your sensitive personal data with investors or other third parties).
Subject to applicable law, where we have a legitimate business need to process sensitive personal data for purposes not identified above, we will only do so where permitted by applicable law and, if required, only after providing you with notice and obtaining you prior, express consent.
HOW WE WILL SHARE YOUR PERSONAL DATA
We will only disclose your personal data to third parties where permitted or required by law or to our employees, contractors, designated agents or third-party service providers and data intermediaries who require the personal data to assist us with administering the recruitment process, including third-party data processors, service providers and data intermediaries who provide services to us or on our behalf. We may use third-party data processors, service providers and data intermediaries for various purposes, including but not limited to obtaining employment verification and background checks and data storage or hosting. These third-party data processors, service providers and data intermediaries may be located outside of the country in which you live or the country where the position you have applied for is located, including the United States of America, Australia, Brazil, Canada, China, Hong Kong, India, Japan, Korea, Mexico, Singapore, Switzerland, the United Arab Emirates, the United Kingdom and the member states of the European Economic Area.
We seek to ensure that all our third-party data processors, service providers and data intermediaries to implement appropriate security measures to protect your personal data consistent with our policies and any data security obligations applicable to us. We do not permit our third-party data processors, service providers and data intermediaries to process your personal data for their own purposes. We only permit them to process your personal data for specified purposes in accordance with our instructions. In no other circumstances will we transfer or disclose any of your personal data to any third party, without your prior consent, unless permitted or required to do so under applicable laws or regulations. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Notice and applicable law.
We and our data processors, service providers and data intermediaries may also disclose your personal data for the following additional purposes where this is permitted or required by applicable law:
- To other Carlyle companies and affiliates such as AlpInvest (including those located outside of your home jurisdiction) for the purposes set out in this Privacy Notice and as necessary to administer the application and recruitment process. In general, our group entities are not permitted to share your personal data with other non-affiliates entities, except as described herein or otherwise permitted by applicable laws.
- As part of our regular reporting activities to other members of our group of companies.
- To comply with legal obligations or valid legal processes such as search warrants, subpoenas or court orders. When we disclose your personal data to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal data necessary for the specific purpose and circumstances.
- To protect our rights and property or if we believe that your actions violate applicable law.
- During emergencies or where necessary to protect the safety of our employees or other individuals.
- Where the personal data is publicly available.
- If a business transfer or change in ownership occurs and the disclosure is necessary to complete the transaction. In these circumstances, we will limit data sharing to what is necessary and will anonymize the data where possible.
- For additional purposes with your consent where such consent is required by law.
We do not sell your personal data and have not done so in the past 12 months, nor do we provide your personal data to third parties for those parties’ direct marketing purposes without having first obtained your consent where this is required by applicable law.
TRANSFERRING PERSONAL DATA ACROSS BORDERS
We may transfer your personal data outside of your country of residence or the country in which the entity to which you are applying is located. These countries (which can include the United States of America, Australia, Brazil, Canada, Hong Kong, India, Japan, Korea, Mexico, Singapore, Switzerland, the United Arab Emirates, the United Kingdom and member states of the European Economic Area) may not be deemed to provide the same level of data protection as in your country of residence. Where required by and in accordance with the measures permitted under the law that apply to our processing of your personal data, we will ensure that your personal data receives at least the same standards of data protection as would be the case in your country of residence, including by:
- Transferring personal data to countries that are deemed by relevant authorities to offer adequate protection for personal data.
- Using standard contractual clauses approved by relevant authorities as ensuring adequate safeguards for personal data.
- Entering into agreements with recipient parties that require them to process the personal data to a standard that is no less than is required by the law in your home jurisdiction.
- Obtaining your consent to transfer your personal data after first informing you about the possible risks of such a transfer.
- Where the transfer is necessary for the performance of a contract between you and us, or if the transfer is necessary for the performance of a contract between us and a third party and the contract was entered into in your interest.
- Where the transfer is necessary to establish, exercise or defend legal claims.
- Working with parties that have implemented Binding Corporate Rules or common intra-group processes and procedures in respect of personal data.
To obtain a copy of the documents used to protect your personal data, please contact us on the details below.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we apply appropriate access limits to access to your personal data. Employees, agents, and contractors will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any data security incident and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW WE WILL RETAIN YOUR PERSONAL DATA
We will process and store your personal data for at least as long as it is necessary in order to fulfil our applicable obligations. Subject to those qualifications, our goal is to keep such data for no longer than necessary in relation to the purposes for which we collect and use the personal data (we refer to the purposes as set forth above).
If you are offered and accept employment with us, the personal data we collected during the application and recruitment process will become part of your employment record, and we may use it in connection with your employment consistent with our Books & Records Policy and Employee and Member Privacy Notice, the latter of which will be provided to you on or around the time you accept the offer. If you have any specific questions in this respect, please feel free to contact us.
If you do not become an employee, we will retain and securely destroy your personal data. We will only retain your personal data for as long as is reasonably necessary in the circumstances and, where permitted by applicable law, for a period of up to 5 years after we have communicated to you our decision about whether to employ you, unless it is in our legitimate business interest to retain the personal data for a longer period, or we are otherwise required or permitted to do so by law. If you are applying to a role in the European Economic Area (EEA) and do not become an employee we will retain your applicant data for up to 2 years, after which we will notify you if we will continue to retain your basic name, contact information, current role, and Carlyle notes related to your application (“Basic Information”), and will retain this Basic Information unless you provide us with updated information or instructed us to delete your information. Your Basic Information may then be retained by Carlyle for 2 additional years, after which all information associated with your Carlyle applicant profile will be deleted unless you provide us with updated information.
Notwithstanding the foregoing, we may seek your consent to retain your personal data for a longer period of time for the purposes of considering you for further opportunities that may arise with us in future.
YOUR PERSONAL DATA RIGHTS
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during the application and recruitment process with us. You can do this by contacting us at firstname.lastname@example.org or by updating your personal data directly using Job Portal.
You have certain rights in relation to your personal data, including the right to:
- Request access to any personal data held about you. This enables you to receive a copy of the personal data we hold about you and to check we are lawfully processing it. In certain cases, we may also be required to provide details of how we have used or disclosed your personal data in the 12 months preceding your request.
- Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected and/or updated.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
- Object to processing of your personal data where we are relying on a legitimate business interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. You may also have the right to object where we are processing your personal data for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to a third party where this is technically feasible.
- Withdraw consent. Where the processing of your personal data is based on consent, you may have the right to withdraw your consent for processing for that purpose at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.
- Right to complain about our processing of your personal data to your national or local data protection authority.
To exercise any of these your applicable rights, please contact us on the details provided below. We will not discriminate against you for exercising any of your applicable privacy rights.
You may be required to verify your identity by answering certain questions and we may not fulfil your request until your identity is verified. You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request. Agents who make requests on your behalf will be required to verify the request by submitting written authorization from you. We will not honor any requests from agents until authorization is verified.
UPDATES TO THIS PRIVACY NOTICE
We keep this Privacy Notice under regular review and it may be amended from time to time. We will update the date at the top of the Privacy Notice accordingly. On some occasions, we may also actively advise you of specific personal data handling activities or significant changes to this Privacy Notice as required by applicable law. Where required, we will inform you of these changes by providing the updated Privacy Notice to you via email or by uploading it to the Job Portal.
We hope that we can satisfy any questions you may have about the way we process your personal data. If you have any concerns, we would appreciate the opportunity to put that right. Please direct your comments and questions relating to our processing of your personal data to email@example.com or firstname.lastname@example.org.
This Agreement is a contract between you and Carlyle Investment Management LLC and its affiliates (referred to below as “The Carlyle Group” or “we” or “us”), and applies only to this Site and not to other Sites that may be accessible from or linked to this Site. We are responsible only for the content of our own Site. We encourage you to review the user agreements of all other Sites that you visit.
The Carlyle Group may change this Agreement from time to time, at our sole discretion. If we make any substantial changes in this Agreement, we may notify you by reasonable means, including by posting a prominent announcement on our home page. Please check this page regularly to ensure that you are familiar with the current version of the Agreement. By your continued use of the Site after publication of the revised Agreement, you accept and agree to the terms and conditions in the revised Agreement.
This Agreement was last updated on August 2, 2017.
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While using the Site, you agree to comply with this Agreement and all applicable laws, rules and regulations, and will not encourage or promote any activity that violates this Agreement.
By accessing or otherwise using the Site, you agree that you will not under any circumstances:
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Notice of Copyright Infringement
The Digital Millennium Copyright Act of 1998 provides recourse for copyright owners who believe that material posted on Internet sites infringes their rights under U.S. copyright law. If you believe in good faith that items, information or other materials appearing on the Site infringes your copyright, please send us a notice containing the following information:
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Please submit this notice to The Carlyle Group at firstname.lastname@example.org.
As our Site indicates, we welcome your questions about us and our financial products and services. Please be advised that any comments, suggestions, ideas or any other information that you send to us through our Site (collectively, your “User Information”) may not be treated as confidential. You hereby grant, and agree to grant, to The Carlyle Group an unrestricted, worldwide, irrevocable, non-exclusive, perpetual, fully-paid, royalty-free, transferrable license to access, view, display, reproduce, adapt, publish, translate, store, host, cache, maintain, modify, distribute, and otherwise use and exploit your User Information in any manner, provided that it is in accordance with the Privacy Notice. You also grant The Carlyle Group the right to sub-license these rights through multiple tiers, and the right to bring an action for infringement of these rights..
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Statement Regarding Internet Phishing and Fraud
Please be aware that bad actors may attempt to misuse The Carlyle Group’s name, brands and reputation by publishing fake websites and engaging in phishing scams seeking personal or confidential information. The Carlyle Group does not authorize such misuse of its name, brands and reputation and investigates these matters to ensure that its legal rights and reputation are protected.
When you communicate with The Carlyle Group through a digital media platform, please remember the following, especially before disclosing personal information:
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Please refer any questions regarding this information to email@example.com.
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Economic and market views and forecasts reflect our judgment as of the date of this presentation and are subject to change without notice. In particular, forecasts are estimated, based on assumptions, and may change materially as economic and market conditions change. The Carlyle Group has no obligation to provide updates or changes to these forecasts. Certain information contained herein has been obtained from sources prepared by other parties, which in certain cases have not been updated through the date hereof. While such information is believed to be reliable for the purpose used herein, The Carlyle Group and its affiliates assume no responsibility for the accuracy, completeness or fairness of such information. References to particular portfolio companies are not intended as, and should not be construed as, recommendations for any particular company, investment, or security. The investments described herein were not made by a single investment fund or other product and do not represent all of the investments purchased or sold by any fund or product. This material should not be construed as an offer to sell or the solicitation of an offer to buy any security in any jurisdiction where such an offer or solicitation would be illegal. We are not soliciting any action based on this material. It is for the general information of clients of The Carlyle Group. It does not constitute a personal recommendation or take into account the particular investment objectives, financial situations, or needs of individual investors.
Critical Information about Transparency in Coverage
This link leads to the machine readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.
Any reference to ESG or impact goals, commitments, incentives, initiatives or outcomes in any statements or communications published on Carlyle.com or through Carlyle’s social media accounts (including any such statements or communications shared by third parties) is not intended by Carlyle to be promoted as an environmental or social characteristic for the purposes of Article 8 of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”), or a sustainable investment objective for the purposes of Article 9 SFDR, and such goals, commitments, incentives, initiatives or outcomes do not bind any investment decisions made in respect of, or the management or stewardship of, any Carlyle funds.