Website Privacy Notice

(Rev. June 2020)

At General Atlantic, we are committed to handling information about you responsibly and we recognize and respect your right to privacy.

This Website Privacy Notice (the “Website Notice”) describes the types of personal information we collect about you, how we may use that information and with whom we may share it.  It also describes the measures we take to protect the security of your personal information and how you can reach us to answer any questions you may have about our privacy practices.  We also describe the manner in which we use your personal data if you apply for a job with us (please see Recruitment Privacy Notice below).  You may also receive other supplemental privacy notices from us if, for example, you become an investor with General Atlantic, or if General Atlantic includes you in its Global Talent Bank.

About Us

We are General Atlantic Service Company L.P.  Our principal place of business is at Park Avenue Plaza, 55 East 52nd Street, 33^rd Floor, New York, NY 10055 (“GA”).  GA has a number of subsidiaries and offices located in various jurisdictions, details of which can be found on the GA website at generalatlantic.com/offices (collectively, “we”, “us” or “our”).

We are a data controller for the purposes of the applicable privacy laws in the jurisdictions in which we operate, including the General Data Protection Regulation 2016/679 (“GDPR”), and  any  applicable  national  data  protection  acts (the “Data Protection Laws”). This means in relation to the personal information you provide to us, we will determine why and how it is used.

What personal information we collect

When you use our website or during the course of our business dealings with you or your employer, we may collect your “personal information”.

Personal information is information that either alone or in combination with other information can directly or indirectly identify you. 

Examples of personal information collected by us include your name, employer/company, job title, telephone number, business and/or personal address(es), email address, information regarding your job, identification numbers (such as a passport number or other government issued ID), and/or other information regarding your preferences where it is relevant to the services that we provide to our portfolio companies and/or investors, or your employment or potential employment with us. We  may  also  ask  you  to  provide  sensitive  types  of personal  data  such  as  any  data  about  religious,  ideological,  political  or  trade  union  views  or  activities,  your  health,  private  life,  the  intimate  sphere  or  racial origin, social security measures (“Sensitive Personal Data”).

How we collect your personal information

We may collect your personal information in circumstances such as:

• when you provide it to us directly (i.e. through this website, or when you contact us via email or provide us with a business card); and
• from a third party source (e.g. from a company for whom you work, other organizations with whom you have dealings, government agencies, a credit reporting agency, a recruitment agency, an information or service provider or from a publicly available record)

If you do not provide information requested by us from time to time, we may not be able to provide services to you or your employer, or otherwise fulfill the purpose for which we have requested the information.

Sensitive Personal Data will only be collected by us if you have provided it to us directly.

How we use your personal information

We will only process your personal information, where:

• you have given your consent to such processing (which you may withdraw at any time);
• the processing is necessary to fulfill a contract we have with you or your employer;
• the processing is necessary for compliance with our legal obligations; and/or
• the processing is necessary for our legitimate commercial interests or those of any third party recipients that receive your personal data.

By “processing”, we mean the collection, recording, storage, use, disclosure and any other form of operations or dealings with your personal information.

We may use personal information about you:

• to provide you with our services and information;
• in connection with our evaluation of an investment or prospective investment in a portfolio company;
• in connection with our evaluation of whether to accept an investment or prospective investment from a prospective investor;
• to send you press kits, newsletters or other marketing or promotional materials; 
• to send you information on news, publications, seminars and events; 
• to improve our services and communications to you; 
• for the purposes of employment, partnership or the supply or retention of services; 
• to process your requests of, and applications to, us; 
• for insurance purposes; 
• to send you invoices or reminder notices; 
• for any other purpose for which this information was provided to us or for any purpose related or ancillary to any of the above; and
• for the Global Talent Bank, as described below.

Sensitive Personal Data may be held for statistical analysis and reporting. 

We may do the following with your personal information:

• record and monitor your use of this website for internal purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;
• use it to provide our services and products and disclose it to third parties (including, but not limited to, our attorneys, accountants, consultants and advisors) who may or may not be part of the General Atlantic group, where such disclosure is connected with the provision of such services and products and permitted by applicable Data Protection Laws;
• use it to market our products and services (this may involve contacting you using the contact details you give us) where we have received your consent to do so, or we believe that you may be interested in the material as it relates to similar products or services you have previously used, or indicated your interest in using, from us;
• transfer it to General Atlantic’s international offices and/or allow the information to be accessed by General Atlantic personnel outside the European Economic Area (“EEA”) as well as within it (you should be aware that in territories outside the EEA laws and practices relating to the protection of personal data are likely to be different and in some cases may be weaker than those within the EEA, please see “Transferring information about you abroad” below for further information);
• share information you provide to us with selected third parties that provide services to us; and 
• store it in an internal database that we maintain of business contacts, which is called the Global Talent Bank, which has a separate privacy notice that can be found here: Global Talent Bank Privacy Notice.

Lawful basis for processing

There is a need to process personal information for the purposes set out in this Privacy Notice as a matter of contractual necessity under or in connection with your applicable agreement with General Atlantic, and/or in the legitimate interests of General Atlantic to operate its business. From time to time, we may need to process the personal information on other legal bases, including: to comply with a legal obligation; if it is necessary to protect the vital interests of an investor or other data subjects; or if it is necessary for a task carried out in the public interest. For the purposes listed above, we are relying on performance of a contract necessity and legitimate interests. Where we are relying on legitimate interest, we have documented legitimate interest assessments.

Who else might receive your personal information

We will share your personal data with the General Atlantic group in other locations around the world. Please see Transferring information about you abroad.  

We may share your personal data with third-party service providers, for example, to host your data, for the purposes described above, and for security purposes. General Atlantic will ensure that third parties accessing your personal data shall comply with the same data protection requirements as General Atlantic and the personal data will be used exclusively for the purposes set out in this Website Notice.

We may also collect, use and disclose personal data or information where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process.  We may share your personal data with authorities to the extent deemed necessary by General Atlantic for the purpose of this Website Notice, in particular, for security reasons or as required by mandatory laws and regulations.

Transferring information about you abroad

Your data may be transferred to our international offices and the various entities that make up the General Atlantic group and accessed by authorized General Atlantic personnel outside the EEA as well as within it. 

You should be aware that in territories outside the EEA, laws and practices relating to the protection of personal data are likely to be different and in some cases may be weaker than those within the EEA. 

We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by applicable data protection law. To find out more about the safeguards we have in place to protect your personal information please contact us as privacy@generalatlantic.com.

Keeping your personal information secure

We will take appropriate technical and organizational measures to keep your information confidential and secure in accordance with our internal procedures covering the storage, access and disclosure of information. Information may be kept on our information technology systems, in the information technology systems of our third party service providers, or in paper files.

What Rights Do EU and EEA Residents Have?

Under the GDPR, residents domiciled in the EU or EEA have certain rights with respect to their personal information. In particular, you have the right to:

• Request access to your personal information;
• Ask to have inaccurate data amended;
• Ask to have your personal information deleted;
• Withdraw your consent to the processing of your personal information;
• Request the prevention or restriction of processing of your personal information for any purpose; and
• Request transfer of personal information to a third party when feasible.

You have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format and have the right to transmit such data to another controller without hindrance from us.

Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless required by law.

Please email us at privacy@generalatlantic.com to exercise your GDPR rights.

What Rights Do California Residents Have?

Under the California Consumer Privacy Act of 2018 and/or its implementing regulations (the “CCPA”), residents domiciled in California have certain rights with respect to their personal information. In particular, you may have the right to:

• information we collect about California residents (and/or, if applicable, sell or otherwise disclose to a third party for business purposes). 
• Choose to opt-out of the sale of personal information. Currently, however, General Atlantic does not sell personal information. 
• Request that we delete the personal information we have collected. Following our verification of the request, we will comply with the request and delete any or all the personal information in our possession that we collected from the California resident and/or any or all such personal information in the possession of our service providers, unless otherwise restricted by law or regulation. 

Please email us at privacy@generalatlantic.com to exercise your CCPA rights.

Non-Discrimination for Exercising Your CCPA Right.

We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights under the CCPA.

How long do we keep your personal data?

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Website Notice.  For example, we may retain personal data we obtain from you when we have an ongoing legitimate business need to do so, or to fulfil an ongoing contract with you or your employer.  

When we have no ongoing legitimate business need or legal obligation to process your personal data, we  will either delete or anonymize it or, if this is not possible (for example, because your  personal data has been stored in back-up archives), we will store your personal data securely  and isolate it from further processing until deletion is possible.

Updates to this Website Notice

We  may update  this Website Notice  from time to time in  response to changing legal,  technical or business developments.  When we update our Website Notice, we  will take appropriate measures to inform  you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by applicable data protection laws, acts or regulations. 

You can see when this Website Notice was last updated by checking the “last updated” date displayed at the top of this Website Notice.  

How to contact us

If  you  have  any  questions  or  concerns  concerning  this  Website Notice  or  the  way  we  process  your  personal  data,  or  if  you  wish  to  exercise  your  data  privacy  rights  as  described  above,  please  contact  us  by  email at privacy@generalatlantic.com, or call our toll-free number at (844) 470-0002. 

Recruitment Privacy Notice

The following provides further information about our handling of your personal information when you apply for a job with us. Please note that this is supplementary to the fair processing information set out above, and you have the same rights as set out above in the recruitment context too.

In connection with seeking employment with us, we may collect your CV, application form, tests and assessment, interview materials and information and opinions related to you.

We may also collect sensitive data including any of the following types of information: racial or ethnic origin; political opinions; religious or philosophical beliefs; union membership; physical or mental health; sexual life; criminal offenses; or criminal proceedings or convictions. 

Such information is maintained for the purpose of evaluating your potential employment with us. Information you provide to us for this purpose may be shared with selected third parties for the purpose of assessing your potential employment. In particular, you should note that your application will be subject to verification. This will involve your references being taken up and any qualification which is indicated on your application being verified by contacting the appropriate body.

The information about you will be used for the purpose of determining your suitability for employment with us. It may also be held for statistical analysis. It may be used for the purposes of legal proceedings (including prospective legal proceedings); obtaining legal advice; establishing, exercising or defending legal rights; compliance with any legal obligation to which the firm is subject; to maintain the security of the firm and its personnel; the prevention and detection of crime or fraud; and compliance with any request from regulatory authorities or other relevant public authorities or agencies.

If your application for employment is unsuccessful, then the information may be retained by us, but in any case for no longer than is necessary for these purposes.

Cookies

What is a cookie?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

What cookies will the site use and for what purposes?

Our website uses a number of different cookies to improve the user experience and help us see what is popular:

• Single session cookies. These enable the site to keep track of your movement from page to page in order to ensure that you will not be asked for the same information you have previously given during your visit to the site. Cookies allow you to proceed through the site quickly and easily without having to authenticate or reprocess each new area you visit. We may use the cookies to analyze user behavior, such as which pages have been visited during the session, in order to improve your overall experience, for example enabling us to determine and display more relevant content.
• Persistent cookies. These cookies enable us to collect information such as number of visitors to the site and pages visited in order to analyze user behavior. This information is collected in an anonymous form and will be collated with similar information received from other users to enable us to compile reports in order to develop and improve user experience by displaying more tailored and relevant content for example. 

How long will the cookies remain on my computer? 

The cookies will remain in the cookies file of your browser after the closing of the browser, and will become active again when the site is reopened, until removed.  The cookie(s) will be deleted after 10 days, but you can delete them earlier at any time. The cookie(s) will not collect any information when you are not accessing the Site. 

Third party cookies 

The single session and persistent cookies are provided on our behalf by a trusted third party service provider to aid in the reporting of user behavior on the website. This behavior is analyzed to provide an improved user experience. The information collected is not linked to personally identifiable information.

We also use Google Analytics help us analyze the use of the Site.  Google Analytics generate statistical and other information about website use by means of cookies, which are stored by users’ web browsers on their computer.  The information generated relating to our website is used to create reports about the use of the website.  Google holds this information and provide us access to it.  Google’s privacy policy is available at Google Privacy Policy.

How to control cookies

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

Complaints

If you wish to make a complaint about how we have handled your personal information, please contact us at the details below and we will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law, you can escalate your complaint to the data protection authority in your jurisdiction, details of which can be found online.

How to contact us

If you have any queries about the contents of this privacy statement, or would like to raise a complaint or comment, please contact us at:

• Email: privacy@generalatlantic.com; and
• Call: (844) 470-0002; and
• Mail: General Atlantic Service Company, L.P., Park Avenue Plaza, 55 East 52nd Street, 33^rd Floor, New York, NY 10055 (or such other address where we have an office in your home country. For further information, see generalatlantic.com/offices).