IRON PARK CAPITAL PARTNERS, LP
We respect our investors’ right to privacy. In the course of conducting business, we collect and maintain certain nonpublic personal information about our former and current individual investors from different sources. Throughout this notice, we use the term “personal information” to describe information that can be associated with a specific person and used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific investor. Specifically, in connection with forming and operating our private investment funds for our limited partners, we collect such personal information from the following sources:
We do not disclose such personal information to any non-affiliated third parties except as set forth below. In the normal course of serving our investors, we may share such personal information with our affiliates or with companies that perform various services for us such as our accountants, auditors, attorneys, fund administrators, consultants, transfer agents, placement agents and other agents, custodians, broker-dealers, service providers, lenders or financial institutions, and as permitted by law. In addition, certain information may be shared with the other investors in the Iron Park Funds, such as the fact that the investor is a limited partner in an Iron Park Fund, its contact information and the amount of its subscription amount. Other disclosures may be made with the consent of investors, such as to the extent provided in the subscription agreement, the partnership agreement and/or other agreements. We require third- party service providers and financial institutions with which we have relationships to confirm that they have implemented and maintain appropriate safeguards to protect the confidentiality of personal information and to use the information only for the purpose for which we disclose the information to them.
We store and process investors’ personal information on our computers in the U.S., and we maintain physical, electronic and procedural safeguards designed to comply with applicable U.S. federal and state regulations. To further protect our investors’ personal information, we permit access only by our authorized employees, affiliates, agents or representatives (including, without limitation, those persons described in the foregoing paragraph) who need access to this information to provide services to us, the Iron Park Funds and the limited partners or other investors. We maintain physical, electronic and procedural safeguards for such information that comply with U.S. federal standards.
We reserve the right to change our privacy policies and this Privacy Notice at any time. This notice complies with the privacy provisions of Regulation S-P. You may have additional rights under other foreign or domestic laws that may apply to you.
Should you have any questions regarding the above, please feel free to call Iron Park Investor Relations (646) 989-2500.
(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.
We are General Atlantic Service Company L.P. Our principal place of business is at Park Avenue Plaza, 55 East 52nd Street, 33rd 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:
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:
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:
Sensitive Personal Data may be held for statistical analysis and reporting.
We may do the following with your personal information:
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 firstname.lastname@example.org.
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:
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 email@example.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:
Please email us at firstname.lastname@example.org 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 email@example.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.
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:
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.
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.
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: