GI Manager L.P. together with its affiliated funds, separate accounts, and management entities (“GI Partners” or “we”) is committed to protecting the privacy of visitors to our website (the “Website”). This Website Privacy Policy comprises generally applicable and
jurisdiction specific-information and where we refer to the “Privacy Policy” below we mean the general sections of this Website Privacy Policy and/or the applicable jurisdictional privacy policies, as the context so requires. This Privacy Policy is intended to help you understand the circumstances in which we may collect your personal information or personal data when you visit the Website and how we use that information or data. “Personal information” and “personal data” as used in this Privacy Policy have the meanings given to them in applicable data protection and privacy laws, and we use these terms interchangeably below for simplicity.
Scope of this Privacy Policy
This Privacy Policy does not address our privacy practices concerning any personal information we collect on or from our investors. We address those practices in separate notices sent to our investors or potential investors.
This Privacy Policy applies when you visit the Website. By using the Website, you acknowledge this Privacy Policy, which may be updated by us at any time. If you do not agree to this Privacy Policy for any reason, please do not use the Website or share your personally identifiable information with us as discussed below. Please note that this Privacy Policy applies only to the Website and not to any other website that may be linked to it. We do not control, and are not responsible for, the privacy policies or practices of other persons or entities, including any other websites accessible from or linked to the Website. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.
Jurisdiction-specific Information
In addition to reading the general sections of this Privacy Policy, if you are:
* Located in the European Economic Area or the United Kingdom, or if the processing of your personal data would otherwise be subject to the European Data Protection Legislation (which includes the GDPR), please read the EU and UK Privacy Policy.
* A resident of California, please read our California Website Privacy Policy.
Contact Us
If you have any questions or comments about this Privacy Policy, you can write to us at Privacy Matters, GI Partners, 4 Embarcadero Center, Suite 3200, San Francisco, CA 94111.
How We Collect Your Information
Personal information is information that personally identifies you or can be used with other information to identify you.
We will collect personal information from you if you voluntarily provide it through the Website, such as by providing your e-mail address and other personal information to receive further information about us.
Please be advised that the virtual data room portals that can be accessed through links on the Website by investors in funds managed by GI Partners are maintained by third-party service providers, whose privacy policies apply to those portals and to the personal information you provide in activating and using your account to access those portals. The third party service providers only inform us of who has access to the portals they operate. We encourage you to review those privacy policies.
The Website is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to the Website who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.
How We Use Your Information
We will use your personal information for one or more of the following business or commercial purposes:
Purpose + Legal Basis to Process Personal Data under the European Data Protection Laws
- To perform services for you, including but not limited to the administrative processes (and related communication) in connection with an investment- Contractual necessity; and/or legitimate interests in operating and improving our business
- To provide you with support and to communicate with you, including processing and responding to requests for information submitted by you through our Website- Legitimate interests in operating and improving our business
- Maintaining a record of your enquires, requests and Website visit- Legitimate interests in operating and improving our business; or legal requirement
- To keep a record of your relationship with us- Legitimate interest in operating our business and providing investment services; and/or legal requirement
- To maintain the safety, security and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity- Legitimate interests in operating and improving our business
- As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order or government regulations- For compliance with our legal obligations
Sharing Your Information
We may use service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and e-mail and providing technical, analytical, and hosting functions for the Website. These companies and individuals (which may include our affiliates) may have access to your personally identifiable information we collect through the Website, as permitted by law and as needed to perform their functions but may not use it for any other purpose. We require that these companies and individuals otherwise keep this information confidential.
If GI Partners is sold to, merges with or transfers substantially all of its assets to, another entity, GI Partners has the right to share your personal information with that entity, its affiliates and its advisors, to the extent lawfully permissible.
We will not otherwise share your personal information, except as required or permitted by law, requested by governmental entity or law enforcement authority, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose us to liability. We can (and you authorize us to) disclose any of your information in such circumstances.
Security
We employ technical, administrative, and physical security measures designed to protect any personal information you provide through the Website from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use the Website and send us such information at your own risk.
*Privacy Policy Changes *
We may revise or supplement this Privacy Policy from time to time and such changes will be posted on this page.
International Use
GI Partners makes no claims that the Website is appropriate or lawful for use or access outside the United States. Access to the Website from countries or territories where such access is illegal, is prohibited.
Please also note that our databases are located in the United States. By sending us your personal information, you acknowledge that this information may be transferred to and stored within the United States.
CALIFORNIA WEBSITE PRIVACY POLICY
This California Website Privacy Policy supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018, as amended (the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Privacy Policy. Individual investor information is protected by federal financial privacy law under the Gramm Leach Bliley Act and not subject to the CCPA.
What does this California Website Privacy Policy apply to?
This California Website Privacy Policy applies solely to your interactions with us through our Website. If you provide personal information to us through another means (e.g., as an investor or an employee seeking employment) you will receive a separate privacy notice and that notice will govern that personal information.
What Categories of Information Do We Collect About You?
We collect, or may collect, limited types of personal information through the Website. The types of personal information we may collect about you depends on the nature of your interaction with the Website. The categories of personal information may collect from individuals on this Website include the following:
A. Identifiers (Name, contact details and address)
B. Internet or other similar network activity (Information you provide to us when you correspond with us in relation to inquiries via our Website)
We do not knowingly collect or solicit personal information from anyone under the age of 18.
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
We collect personal information for the business or commercial purposes and from the sources set forth in “How We Use Your Information” and “How We Collect Your Information,” respectively, in the Privacy Policy above. We retain the categories of personal information set forth above in “What Categories of Information Do We Collect About You?” section of this California Website Privacy Policy only as long as is reasonably necessary for those purposes set forth in “How We Use Your Personal Information” in the Privacy Policy above, except as may be required under applicable law, court order or government regulations. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information and the purposes for which we process your personal information and whether we can achieve those purposes through other means.
Who Do We Disclose Your Personal Information To?
We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
We will not disclose your personal information, except as required or permitted by law, requested by governmental entity or law enforcement authority, subpoena, court order or discovery request, or when we otherwise believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose us to liability.
We take measures to protect your personal information as set forth in “Security” in the Privacy Policy above.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
*Disclosure and Access Rights: *You have the right to request that we disclose to you certain information regarding our collection, use, and disclosure of personal information specific to you. Such information includes:
* the categories of personal information we collected about you;
* the categories of sources from which the personal information is collected;
* our business or commercial purpose for collecting such personal information;
* the categories of third parties with whom we disclose the personal information;
* the specific pieces of personal information we have collected about you; and
* whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
*How to Exercise Your Rights: *These rights are not absolute, and we reserve all of our rights available to us at law in this regard. To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact Us section below.
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. We do not distribute your personal information to outside parties for their direct marketing to you without your consent.
Contact Us
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request to [email protected].
If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at legal @gipartner.scom and we will call you between 9 a.m. and 6 p.m. Pacific Time.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Please contact [email protected] with any questions about this California Website Privacy Policy.
EU and UK PRIVACY POLICY
For the purposes of Regulation (EU) 2016/679 (the “EU GDPR”), and the EU GDPR as it forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the “UK GDPR”), and all other applicable laws in the EEA or UK relating to privacy or the processing or protection of personal data (together with the EU GDPR and UK GDPR, the “European Data Protection Laws”), GI Manager L.P. is the controller of any personal data collected by us via the Website.
This section supplements our Privacy Policy and only applies to you to the extent that your personal data collected by us via the Website is subject to the European Data Protection Laws. Please read both the Privacy Policy and this EU and UK Privacy Policy carefully. You do not need to take any action as a result of this section of our Privacy Policy, but you do have certain rights as described below in the section headed “Your rights”.
Collection, use and sharing of your personal data
The personal data that we collect and who we share such personal data with are described above and below.
We do not collect any special categories of personal data about you via the Website (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, personal data about your health and genetic and biometric data). We also do not collect any personal data about criminal convictions and offences via the Website.
The Website is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to the Website who are under the age of 13 or knowingly collect personal data from anyone under the age of 13 without parental consent. If we learn we have collected or received personal data from an individual under the age of 13, we will delete that information.
Our legal bases
We rely on various legal bases under the European Data Protection Laws in order to process your personal data, including our legitimate interests, contractual necessity and as required by law. Please see the “How We Use Your Information” section of the Privacy Policy for further information.
*Why we use your personal data *
To the extent that you provide us with any personal data, through or in connection with the Website, we may use such personal data for the purposes listed in the “How We Use Your Information” section of the Privacy Policy.
We may ask you to provide some of the personal data referred to in the Privacy Policy and this EU and UK Privacy Policy for one or more of the purposes described above. If you fail to provide this personal data when requested, and it is necessary for us to comply with our legal or contractual obligations, we may not be able to meet the obligations placed on us. In all other cases, the provision of your personal data is voluntary.
We may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.
No automated decision-making, including profiling, is used when processing your personal data.
*Retention of your personal data *
We will keep your personal data only for as long as is reasonably necessary for the purposes set out in the “How We Use Your Information” section of the Privacy Policy, unless a longer retention period is required by law. We will not keep more personal data than we need for those purposes. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data and the purposes for which we process your personal data and whether we can achieve those purposes through other means. For further information about how long we will keep your personal data, please contact us.
*International transfers *
As noted above, GI Partners’ databases and certain entities in our group are based in the U.S. In addition, certain of those third parties that we share your personal data with (as described above) may be located outside of the EEA or UK. As such, we may transfer your personal data to such affiliates and third parties. Where we do so, we will do so in compliance with European Data Protection Laws, including through the use of standard contractual clauses approved by relevant authorities. Please contact us for more information on how we make such transfers.
Your rights
You have certain rights in relation to the personal data we hold about you. To exercise these rights, please contact us as directed in the Privacy Policy.
- Access: You have the right to ask for a copy of the personal data that we hold about you.
- Correction: If there are any inaccuracies in the personal data we hold about you, please contact us and we will correct them.
- Deletion: If you think that we should not be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (unless the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your personal data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing and we are verifying whether our legitimate grounds to process your personal data override your own rights.
- Object: You have the right to object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we will demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
- Portability: Where we are processing your personal data based on your consent or for performance of a contract with you, you have the right to request that we transfer your personal data to a third party controller in a secure manner, but only where it is technically feasible to do so without affecting the rights of other individuals.
- Withdraw consent: In the limited 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. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
- We will respond to your requests as soon as possible and (save for in certain circumstances) within one month. Although we will usually do so free of charge, we may charge a reasonable fee if we think that your request is excessive to help us cover the costs of addressing the right or rights you have requested (or alternatively we may refuse to comply with the request in such circumstances).
- We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Contact Us
If you have any questions or concerns about this EU and UK Privacy Policy, please contact us as directed in the Privacy Policy.
Complaints
If you have any complaints regarding how we use your personal data, we would appreciate the opportunity to discuss those concerns with you in the first instance.
However, should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact:
* In relation to the UK GDPR, the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.
* In relation to the EU GDPR, your local supervisory authority in the EU Member State of your habitual residence, place of work, or place of the infringement concern or complaint.
*