Governance

This Privacy Notice describes how Apollo Global Management, Inc. (together with its subsidiaries and affiliates “Apollo”, “us”, “we” or “our”) gathers and uses personal information about you when you communicate with us and when you visit this website and any other of Apollo’s websites that link to this Privacy Notice (collectively, the “Sites”); how we protect and share this information; and the rights you may have in relation to this information.  When you are a fund investor or job applicant, our information practices are explained in separate notices such as our subscription materials or candidate privacy notice.  Please read this Privacy Notice carefully, and consult our Terms of Use for more information about the general terms and conditions regarding your use of the Sites.

If you are a California Resident (as defined below), please review the below section Additional Information for California Residents for additional disclosures and Notice at Collection and Use of Personal Information for a description of your rights under the California Consumer Privacy Act (with any implementing regulations, as amended by the California Privacy Rights Act (“CPRA”), and as may be amended from time to time, “CCPA”).

In the event that you have any questions or concerns about this Privacy Notice, if you object to our uses of your personal information, or if you wish to exercise your rights under applicable law, please contact us at privacy@apollo.com.

When you visit and browse the Sites or communicate with us, you may directly provide us with information, including personal information, and we will collect certain information automatically or through other sources.  When we use the term “personal information”, we mean any information that can help us directly or indirectly identify you and as otherwise defined under applicable law. Apollo.com

In order to access certain services provided via the Sites or to request certain information from Apollo via the Sites, you may be required to provide certain personal information.

Depending on how you interact with us and which Site you are visiting, including if you are vendor that we interact with, we may collect the following categories of personal information from or about you:

• identifiers and similar information such as, name, address, date and place of birth, email address, telephone number, social security number or other unique identifier number, tax identification number, driver’s license number, passport and other national identity details, internet protocol (“IP”) address, username, password, online identifiers or other similar identifiers;
• certain financial information protected under federal or state laws, like a signature, bank account, or other financial information;
• personal details, including characteristics of protected classifications under certain federal or state laws, such as gender or marital status, or information that might be considered special category data or otherwise sensitive under applicable law, including, racial or ethnic origin;
• commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies, including funds invested, investments considered, or sources of wealth;
• education information, including information that is not publicly available, and personally identifiable information as defined in the Family Educational Rights and Privacy Act;
• internet or other electronic network activity information, including certain technological information like interactions with our Site or use of certain online tools;
• audio (e.g., voicemail), electronic, visual or similar information;

professional or employment-related information, including occupation, compensation, employer, title, certifications, professional license numbers; and

inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information.

Please note that some of this information may be considered special category data, or sensitive data under applicable law.

You may also be required to provide a username and password to access certain features.  If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Sites, which rely on such information (for example, you will not be able to register for e-mail updates if you do not provide us with an e-mail address, and if you choose not to provide a username and password, we will not be able to provide you with services available through an online account).

We also collect information about you automatically, which may include personal information.

For example, when you visit the Sites, we collect your IP address, your browser type, your operating system, the pages you view on the Sites, the duration of your visit, the pages you view immediately before and after you access the Sites, and the search terms you enter on the Sites.

We generally collect this information using cookies.  For more information on our use of cookies and other technologies, please review Our Use of Cookies and Similar Technologies below.  Other technical methods including web beacons may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf.  We may also use these technical methods in HTML e-mails that we send visitors to the Sites to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.

If you communicate with our employees and other staff members via email, telephone, or other electronic channels, our information technology systems record details of those communications, sometimes including their content, for compliance and record-keeping purposes.

We may collect personal information about you from other sources such as our service providers or other vendors that assist with our business.  Additionally, some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.

The third-party partners from which we receive personal information include web hosting providers.  We may receive information related to name, occupation, address, and contact information from such third-party partners.  Our use of information received from such a third-party will be dictated by the third party’s privacy policy and not this Privacy Notice.

We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third-parties.

We use cookies, web beacons and other similar technologies for a variety of purposes such as to better understand, customize and improve the user experience of our Sites, services and offerings, and market to you. Cookies are small files that a website sends to your computer or device while you are viewing the website, or other technical methods to track visitor usage, including web beacons, which are small pieces of data that are embedded in images on the pages of a website. For example, when you return to our Sites after logging in, cookies provide information to the Sites so that the Sites will remember who you are. Cookies may also be used by our service providers or other business partners.

For more detailed information and to update your preferences, go to the cookies page.

The Sites may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.

Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information.  We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Sites).  These links are provided to you for convenience purposes only, and you access them at your own risk.

How we use your personal information may vary depending on how you interact with us and which Site you are visiting.  Generally, we use information we collect about you primarily to provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other investors, as permitted by applicable laws.

We may collect, use or process your personal information for the following business or commercial purposes, and the lawful bases for our processing include the following:

• respond to your requests for forms, literature, or information, on the basis that it is in our business interests to respond to your requests, and you have requested that we do this;
• manage and administer customer services, including but not limited to the administration of your customer account. In most cases we do this is to meet our contractual obligations to you.  Where there is no such obligation, we have a business interest in keeping our records accurate and up to date, which will assist you when we provide our services;
• process transactions as necessary to meet our contractual obligations to you;
• provide you with the services you have requested. In many cases we will provide these services to comply with contractual obligations to you, but if these services are not governed by any contract, we will use your information in this way to meet our business interests in providing the best service possible;
• prepare investor disclosure materials. This is necessary to comply with our legal obligations, to meet our interests in managing our business effectively, and for informing you and our other investors about how we are meeting your expectations;
• improve the Sites and learn about how visitors use the Sites. This is necessary for us to improve the services we offer through the Sites, and benefits you as it helps us make the Sites more usable and appealing;
• maintain security and prevent or detect crime and fraud. In many cases we are required to do this by applicable laws, but will otherwise do so to meet our legitimate interests in maintaining security and preventing crime;
• communicate with you about our products and services and support our business development and marketing initiatives, including providing you with information about features on the Sites and possible changes to our Privacy Notice or Terms of Use. If required by applicable law, we will only send these direct messages on the basis that you have consented, or otherwise it will be to meet our business interests in providing information to our investors about new products and features.  You can opt out of receiving such marketing communications at any time by using the information in Your Choices and Rights;
• internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This processing benefits investors by supporting our provision of services;
• with your consent (including explicit consent), as required under applicable law.
• comply with legal obligations; and
• protect our rights, your rights, and the rights of others, as this may be necessary to meet our own high standards of business practice, as well as establish, exercise or defend legal claims.

We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you.  For example, we may prepare aggregated reports about how visitors tend to interact with the Sites for research about the use of the Sites and how the Sites could be improved, from which your interactions with the Sites cannot be singled out.

We may share information about you with third-parties when you engage in certain activities on the Sites that are sponsored by third-parties.  For example, you may choose to purchase products or services offered by a third-party or elect to receive information or communications from a third-party.  If you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third-parties in association with the offerings.

We may disclose this information to third-parties for the purposes and on the basis described above (see Section B), for example, to process your transactions and to respond to your requests for information or communications from third-parties.

Sometimes we engage companies that process information for us or act on our behalf in association with the operation of the Sites and our services.  For example, such companies may deliver products or services, improve the functionality of the Sites, collect information about you, communicate with you, or store information for us.  In some cases, these companies may need to access information about you.

We may also disclose your information to service providers that provide products or services to us or to facilitate our business operations, including marketing, advertising and related services.

Except as otherwise disclosed in this Privacy Notice or as otherwise communicated to you, Apollo takes reasonable steps to require these companies to collect, store, and use information about you only on our behalf and in accordance with this Privacy Notice.  We share personal information with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.

We may engage analytics providers to help us understand how users engage with the Sites.  These providers may use cookies and similar technologies to collect information about your use of the Sites as well as information about your use of other websites over time.

The services we use include, but may not be limited to:  Google Analytics and Adobe, which may provide you with choices about how they collect and use information.  As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.  To find out more about how Google Analytics collects and processes data, please click here.  Google Analytics has its own cookies that it uses to track and aggregate this information.  You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.

We may share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above.  We may also partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.

We may disclose information when we believe in good faith that such disclosures:

• are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request;
• will help to protect our rights or enforce our Terms of Use;
• will support our detection, prevention, or response to fraud or intellectual property infringement;
• at your direction or with your consent;
• will help protect your safety or security, including the safety and security of property that belongs to you; and
• will protect the safety and security of the Sites, databases, and/or third-parties, including the safety and security of tangible and/or intangible property that belongs to us or to third-parties.

We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.

The above-described disclosures are provided on the basis that they are either necessary to comply with our legal obligations or they are necessary to meet our legitimate interests in managing our business efficiently and for developing future business.

Additionally, we reserve the right to share with third-parties information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.

We do not sell your personal information and have not done so in the last 12 months from the effective date of this policy.

Please note that for purposes of this Section E, “sharing” does not include “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review Additional Information for California Residents below.

We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive.  Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

You may update your contact information and/or modify your communication preferences by sending us an e-mail at privacy@apollo.com.  Additionally, we may provide tools on the Sites that facilitate such updates or modifications.

The Sites are intended for use by those over 18, and minors under the age of 13 may not use the Sites.

We do not knowingly solicit or collect personal information on the Sites from children under the age of 13.  If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking.  We do not currently respond to such signals.

Third-parties, such as our analytics providers, may collect data that relates to you on the Sites, across time, and over other websites.  We cannot control third-parties’ responses to do-not-track signals or other such mechanisms.  Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

If you no longer wish to receive marketing materials from us, you can let us know by contacting us at privacy@apollo.com or using other unsubscribe features that we provide in our marketing communications.

Subject to local law, you may have certain additional rights regarding your personal information.  These may include the following rights to:  (i) access your personal information; (ii) rectify the information we hold about you; (iii) erase your personal information; (iv) restrict our use of your personal information; (v) object to the processing of your Personal Information in certain circumstances, including where we process Personal Information for direct marketing purposes or where we have processed such data on the basis of our legitimate interests; (vi) withdraw your consent to the processing of your Personal Information (where applicable); (vii) receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); and (viii) lodge a complaint with your local data protection authority, and withdraw any consent you have given to uses of your personal information.

If you are a California Resident, please review Additional Information for California Residents below for a description of your California-specific rights regarding your Personal Information.

If you would like to discuss or exercise the rights you may have, contact us at privacy@apollo.com or call us toll-free at 833-271-8296.  We will review your request and respond accordingly.  The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.

We will process your request within the time provided by applicable law.

If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes.  If you wish to exercise this right, please email us at privacy@apollo.com.  For additional information about your rights under the CCPA and how to exercise those rights, refer to the Additional Information for California Residents.

Our activities and the jurisdictions in which we are established are such that we process information collected via the Sites in and subject to the laws of the United States and other countries, which may not provide the same level of protection for your information as your home country.  The information may be available to the United States government or its agencies under a lawful order made in the United States.  In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.

In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union or other applicable laws.  However, we will seek to ensure that a similar degree of protection is afforded to your personal information by ensuring that, where possible, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements, or otherwise transfer personal information in accordance with applicable laws, such as, where the transfer is necessary for the performance of a contract between you and us or between us and a third party in your interest, where the transfer is necessary to establish, exercise or defend legal claims, or where the transfer is made for important reasons of public interest.  For more information on the appropriate safeguards in place or to obtain a copy, please contact us at privacy@apollo.com.

We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.

When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators.  We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.

The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.”  If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA.  The rights described herein are subject to exemptions and other limitations under applicable law.

Terms used herein have the meaning ascribed to them in the CCPA.  We are a “business.”  

Information We Collect

Depending on how you interact with us, and which Site you are visiting, we may collect the categories of personal information listed above in The Types of Information We Collect and How We Collect It.

Our Use and Collection of Information

We may collect and use personal information from you for the purposes described above in How We Use the Information We Collect.

Sale or Sharing of Personal Information

We do not “sell” your personal information under the CCPA, meaning we do not rent, release, disclose, transfer, make available, or otherwise communicate personal information to another business or third party for monetary or other valuable consideration. We also do not “share” your personal information, as defined under the CCPA to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

How Long We Keep Information

We retain your personal information as described above in the section How Long Is Information Retained?

For more information about our privacy practices, please review our entire Privacy Notice.

What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information

In the preceding 12 months, depending on how you interact with us and which Site you are visiting, we may have collected the categories of personal information from the categories of sources listed above in the section, The Types of Information We Collect and How We Collect It.  We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section How We Use the Information We Collect.

Our Disclosure of Personal Information

We do not sell or share your personal information (as those terms are defined under the CCPA).  We do not knowingly sell or share the personal information of California Residents under 16 years old.   In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information (described in more detail in The Types of Information We Collect and How We Collect It above) to the following categories of third parties, as describe in the below chart:

In addition, we may disclose and in the preceding 12 months, may have disclosed for all of the categories of personal information identified in The Types of Information We Collect and How We Collect It above to the following categories of third parties:  (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose the categories of personal information identified in The Types of Information We Collect and How We Collect It for the business or commercial purposes identified above in How We Use the Information We Collect.  Additionally, we may disclose your personal information to third parties upon your request, at your direction, or with your consent.

We may also disclose your personal information or otherwise make it available to our service providers such as our IT and/or CRM providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.

Use and Disclosure of Sensitive Personal Information

As noted in The Types of Information We Collect and How We Collect It, we may collect certain special category data or sensitive personal data under certain laws. We do not currently collect “sensitive personal information” (as defined under the CCPA) from our website visitors. We may collect “sensitive personal information” from our investors or job applicants, as explained in separate notices such as our subscription materials or candidate privacy notice.    

If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to:  (i) be informed, at or before the point of collection, of the categories of personal information to be collected, and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit); (vii) correct inaccurate personal information (“Request to Correct”); and (viii) request that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months (“Request to Know”).

The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations.  In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the GLBA.  We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.

You may submit a Request to Know, Request to Correct or Request to Delete (“Consumer Rights Request”), as described above, through the following toll-free telephone number 833-271-8296 or email us at privacy@apollo.com.

When you submit a Consumer Rights Request may ask that you provide clarifying or identifying information to verify your request.  Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address.  Any information gathered as part of the verification process will be used for verification purposes only.

If you would like to use an authorized agent to submit a request, we may request proof that that they are authorized to act on your behalf, or have a power of attorney.  We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.

We may change this Privacy Notice from time to time.  Should we do so, we will post the changes to this page.  We suggest that you periodically consult this Privacy Notice to review any changes.  Your continued use of the Sites after the effective date of any modification to the Privacy Notice will be deemed to be your agreement to the changed terms.

This Notice was last updated January 1, 2023.

This Privacy Notice is available in alternative formats upon request.  If you have any questions regarding this policy or our privacy or data protection practices, or to request this Privacy Notice in an alternative format, please feel free to contact us at privacy@apollo.com.

It has come to our attention that certain credit and identity monitoring companies may be incorrectly attributing a July 2018 data breach at sales intelligence company Apollo.io (https://www.apollo.io/) to Apollo Global Management (www.apollo.com).  Apollo Global Management has no relationship with Apollo.io.  Individuals who have received notice of this breach should notify their credit/or identity monitoring company of the error and contact Apollo.io pursuant to that company’s privacy policy (https://www.apollo.io/privacy/).