Privacy Policy
Effective Date: September 30, 2026
Pine Brook Road Partners, LLC, including its affiliates (“Pine Brook Partners”, “we”, “us” or “our”) Online Privacy Policy (“Policy”) describes how Pine Brook Partners may collect, use, retain, and share Personal Information (defined below) and data during users’ interactions with our Services (“users,” “you,” or “your”) provided by Pine Brook Partners in the United States. Specifically, this Privacy Policy describes how we collect, use, and disclose your Personal Information when you:
- Access and use of our websites, including https://pinebrook.ovenholdings.com/ and the associated Investor Portal (the “Site”).
- Make use of any of our services, use our software, register for an account, subscribe to our communications, register for our events, send us a message, or otherwise access or use the various content, features, and other services offered by us through our Site (collectively, the “Services”).
Please note that this Policy does not apply to information collected through means other than the Site. Certain Personal Information collected in connection with Services related to Pine Brook Partners’ investment fund management business activities and services are governed by a separate privacy notice and applicable agreements, as required by applicable law (collectively, “Investment Agreements”). If any provision of this Policy is inconsistent with or conflicts with any provision of the Investment Agreements, the Investment Agreements shall govern and control.
Agreement to the Policy
By using the Site, you consent to this Policy and agree that we may collect, use, retain, share, transfer and disclose of information about you in accordance with the data practices described in this Policy. “Personal Information” means information that can reasonably be linked to a particular individual or household or as otherwise defined by applicable data protection laws. The Personal Information we may collect depends on your level of engagement with the Services.
This Privacy Policy is intended to be read together with our Website Terms of Use. By accessing or using our Site or Services, you also agree to be bound by our Website Terms of Use, which govern your use of the Site in addition to this Policy.
Changes to our Privacy Policy
Pine Brook Partners may modify the Policy at any time to reflect updates to its data practices or the law, so please review it periodically. If we make changes to the Policy, we will post the updated Policy to this Site reflecting these changes and indicate at the top of the Policy the date it was updated, unless additional notice is appropriate or required by law. Any revisions to the Policy become effective when we post the revised Policy on the Site. Your use of the Site following these revisions means that you accept the updated Policy.
Sources of Personal Information Collection
We may collect Personal Information from a variety of sources, including directly from you and your interactions with our Services. We may also obtain information about you from other sources, including through third-party services.
What Information We Collect
Pine Brook Partners collects the following types of information, some of which may, alone or in combination with other information we have, identify or relate to you (“Personal Information”):
Identifiers
We may collect identifiers when you voluntarily provide them to us. These include:
- First and last name
- Phone number
- Information from communications
- We collect information you provide to us in communications, such as through customer support requests
- Tax information you provide to us
- Any other identifiers you provide to us
Online Activity and Technical Information
We collect technical-related Personal Information when you use the Site or our Services, including:
- Date and time of your use of the Site or Services
- Names of requested files
- Pages from which any files are requested
- Information about how you use the Services
- Location information of your devices interacting with the Site
- Full IP address of devices used to access the Services
- Access status of any relevant files (file transferred, file not found, etc.)
- Type and version of browser and operating system used to access the Site or Services
- Quantity of data transferred
- Wi-Fi network information
Purposes for Which We Collect and Use Your Information
Pine Brook Partners may collect, use, and disclose the information we collect in a variety of ways to enhance your experience while using the Site and Services, including:
- Monitor metrics such as total number of visitors, traffic, and demographic patterns;
- Provide, improve, test, and monitor the effectiveness of the Site;
- Improve customer services and Pine Brook Partners’ products and offerings, facilitate usage of the Services, engage in research, and as otherwise needed to manage our business;
- Respond to your questions;
- Communicate with you regarding our protected content, such as annual meeting content and videos, as well as to provide you with information about additional products and services you may be interested in;
- Monitor and ensure Site integrity and security;
- Conduct risk management, investigate, prevent, protect or take action relating to illegal activities, including fraud, unauthorized transactions and other risks or liabilities, violations of our Terms of Use or this Policy;
- Secure our Services by identifying potential hackers and unauthorized users; and
- Comply with applicable legal, regulatory, or self-regulatory requirements, including anti-money laundering (AML) and know-your-client (KYC) obligations.
Cookies and Similar Technologies
To facilitate easy navigation within the Site, we or our service provider(s) may use cookies (small text files stored in a user’s browser), web beacons (electronic images that enable counting visitors who have accessed a page or certain cookies) or other similar technologies to collect technical data resulting from your activity on the Site, which we may coordinate with your account information.
Pine Brook Partners and its webmasters use this information to help us understand how the Site is being used and how to generally improve your experience when using the Site. For example, we may use cookies and similar technologies to analyze the number of visitors to each landing page, to determine which areas of the Site are the most visited, and to analyze information about users who access our password protected content, such as annual meeting content and other videos, or who access our Site after reading an email from Pine Brook Partners. For more details on cookies please visit All About Cookies.
Use of our Site could generate the following types of cookies:
- “Necessary” cookies, which are cookies that are necessary for the Site to function properly. Some of the following actions can be performed by using these cookies:
- Saving your cookie preferences for the Site
- Saving language preferences
- Logging in to our portal. We need to check whether you are logged in.
- “Performance” cookies, which are cookies that are used to gather statistical information about the use of the Site, also called analytics cookies. We use this data for performance and Site optimization.
- “Functional” cookies, which enable more functionality for our Site visitors. These cookies can be set by us or our external service providers.
- “Unclassified” cookies, which are cookies that are still in the classification process. They will show up in one of the following categories: Necessary, Performance, Functional, or Advertising.
Cookies stay on your device for different periods of time depending on the type of cookie that is placed. These include:
- Session cookies. We use session cookies, which are temporary cookies that remain on your device until you leave our Site.
- Persistent cookies. We also use persistent cookies, which remain on your device for a longer period of time to remember your preferences.
Pine Brook Partners does not collect Personal Information about an individual’s online activities over time and across third-party websites or online services, other than as described in this Policy.
Google Analytics
We use, and/or some of our third-party service providers may use, Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to track, examine, and help us analyze how users use our Site, as well as to enhance your experience when you use the Site. Google may use the Personal Information collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. For more information on how Google uses this data, go to https://support.google.com/analytics/answer/12159447?hl=en. For information on Google Analytics’ cookies expiration, read here. You can prevent your data from being collected by Google Analytics on our Site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser at the following link: Google Analytics Opt-out Browser Add-on.
You can control whether your computer or device will allow cookies. To do so, consult your browser settings, which generally can be found in the “help” section on the browser toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Please note that if you set your browser to disable cookies or other technologies, you may not be able to access certain parts of the Site or parts of the Site may not work properly.
Global Privacy Control. Certain U.S. state residents may opt out of tracking technologies by broadcasting an opt-out preference signal, such as the Global Privacy Control (“GPC“) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC signal, click here. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use. If this signal is employed while visiting our Site, we will stop data sharing immediately.
Please note that honoring GPC and similar signals does not stop all data collection on our Site. We may continue to collect and use personal information for purposes that are allowed by law, such as to provide our Services, measure Site performance, prevent fraud and security incidents, or comply with our legal obligations.
Sharing Your Information
In certain circumstances we may share your Personal Information with unaffiliated entities without further notice to you, unless required by the law, as set forth below:
- Vendors and Service Providers; Data Analytics. To assist us in providing the Site, meeting business operations’ needs, and performing certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology service providers; email communication software and email newsletter services; advertising and marketing services; customer relationship management and customer support services; and web analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.
- Affiliates. We may disclose Personal Information collected from the Site to our affiliates, meaning an entity that controls, is controlled by, or is under common control with us, in order to communicate with you, provide the Services, or achieve any other purpose described in this Policy. Our affiliates may use Personal Information we share in a manner consistent with this Policy.
- Legal Requirements. We may disclose Personal Information collected from the Site to law enforcement, regulatory, government agencies, or third parties pursuant to legal process or as otherwise required by law, or, in our sole discretion, to protect our rights, property or interests, or to enforce this Privacy Policy or our Terms of Use. For example, we may disclose Personal Information to:
- Protect and defend the rights, property, or safety of Pine Brook Partners, our employees, other users of the Services, or the public;
- Respond to a legally valid request from a competent governmental authority;
- Respond to claims that any content violates the rights of third parties;
- Correspond with law enforcement agencies, if we are required to do so; and
- Satisfy any applicable law, regulation, or legal process.
- Business Transfers. If we are involved in a merger, acquisition, change of ownership, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
Data Integrity and Security
We use commercially reasonable safeguards to help keep the information collected through the Site secure. However, no information security safeguards can be guaranteed to be completely secure. As a result, Pine Brook Partners cannot ensure or warrant the security of any information you transmit to us, or guarantee that your information on the Site may not be accessed, disclosed, altered, or destroyed while in transmission to or in storage with Pine Brook Partners.
Links to Third-Party Websites
The Site may contain links to other web sites, such as our investor portal hosted by eFront. We have no control over and are not responsible for the privacy policies or practices of such sites. Whenever you link to another web site, you may be asked to provide registration or other information. Please note that any information that you provide after leaving this Site is going to a third party, and therefore you should familiarize yourself with that party’s privacy policy.
United States Rights. Certain states in the U.S., e.g. California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights related to their Personal Information. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances. To the extent that these laws apply, you may exercise the following rights:
- Right to Know and Access Information. Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy. With this said, you have the right to know about our information practices. You also have the right to access the categories of data we collect, with whom we share or sell that information, and, in some cases, what specific Personal Information we associate with you or your account.
- Right to Data Portability. If you request a copy of your specific information then we will provide it in an easily accessible format.
- Right to Deletion or Erasure. You may request that we delete the information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it.
- Right to Correct Information. You may request we correct or rectify inaccurate information we have collected about you.
- Right to Opt-out of Targeting Advertising, Sales, or Profiling. You may opt-out of our use of your Personal Information for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.
We do not knowingly collect or sell information from children under the age of 16.
Appeal. If we deny your rights request, you have the right to request an appeal of our decision. To initiate an appeal, follow the instructions provided in the communication denying your request, or contact us at the contact information provided in this Privacy Policy.
Non-Discrimination. You have the right to not experience discrimination from us for exercising the rights listed in this section. What we mean by discrimination is denying you access to our Site or limiting the quality of our Site.
Email communications. You may control how you receive certain types of email communications by unsubscribing within the body of the communication. Note that some messages are required, service-related messages such as transaction confirmation messages, legal notices, or updates of which you may not opt-out.
Rights Under EU, Swiss, and UK Law. Our Site and Services are intended for users located in the United States. However, if you are accessing our Site or Services from outside the United States, certain privacy rights may apply to you under applicable local laws. Users residing in the EU, UK, and Switzerland may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. Consistent with these laws, we give you options to access, edit, or remove certain information, as well as choices about how we contact you. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances.
To the extent that these laws apply, you may exercise the following rights:
- Right to Access. Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy. With this said, you have the right to know about our information practices. You also have the right to access the categories of data we collect, with whom we share or sell that information, and, in some cases, what specific Personal Information we associate with you or your account.
- Right to Rectification. You may request we correct or rectify inaccurate information we have collected about you.
- Right to Erasure. You may request that we delete the Personal Information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it.
- Right to Restrict Processing. If we process your information based on our legitimate interests as explained in this Privacy Policy, you may have the right to restrict processing in certain circumstances.
- Right to Object. If we process your information based on our legitimate interests as explained in this Privacy Policy, or in the public interest, you can object to this processing in certain circumstances. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings.
- Right to Data Portability. If you request a copy of your specific information then we will provide it in an easily accessible format.
- Right to Lodge a Complaint. You may be entitled to lodge a complaint with your data privacy regulatory authority.
We generally process Personal Information of those residing in the European Union on the legal basis of our legitimate interests in performing the function or service you requested. Where appropriate, we may rely on alternate legal bases, such as your consent to certain types of processing. Where we process your Personal Information on the basis of consent, we will clearly obtain your opt-in consent.
Other Jurisdictions. Other individuals residing in other countries and jurisdictions, including Hong Kong, Japan, Mexico, New Zealand, Singapore, South Korea, and certain other jurisdictions may be entitled to various data subject rights. Depending on your country of residence, these rights may vary. The rights may include, but are not limited to, the rights listed above, such as the right to opt out of collection and use, the right to access, the right to data portability, the right to withdraw consent, and the right to lodge a complaint with your relevant supervisory authority. If you are a citizen of one of these countries and wish to know more about your rights and options, please contact us through the “Contact Us” section.
Children’s Privacy
Pine Brook Partners does not knowingly collect or solicit Personal Information from any persons under the age of 16 or knowingly allow such persons to register for the Site. The Site and its content are not designed for or intentionally directed to children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Information to us through the Site please contact us using the information below and we will endeavor to delete that information from our databases.
Verification. In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.
Authorized Agents. You may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, we may require the agent to present signed written permission to act on your behalf and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
Contact Us
For any questions, comments or concerns, or if you would like to view this Policy in an alternative format, please contact us at Pine Brook Partners at [email protected] or at 212-847-4333.