Our Commitment to Your Privacy
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, the European Union 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
We do not collect any personal information from you through the Website except as described below. 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.
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 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
The security of your information is important to us. We employ several different technical, administrative, and physical security measures 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 data, you acknowledge that your personal data 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. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
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:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, contact details and address. | YES |
| B. Internet or other similar network activity | Information you provide to us when you correspond with us in relation to inquiries via our Website. | YES |
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.
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 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, disclosure and sale 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: 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.
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 legal@gipartners.com.
If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at legal@gipartners.com 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 legal@gipartners.com with any questions about this California Website Privacy Policy.are located in the United States. By sending us your data, you consent to its transfer to and storage within the United States.