WEBSITE PRIVACY POLICY
(Rev. October 2023)

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

This General Privacy Notice (the “Privacy 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.

Unless otherwise indicated, this Website Privacy Notice applies only to information collected with your use of the public sections of our Website or from interactions we may have with you directly at conferences, meetings, events, our office or your office, or otherwise in other public places. In addition to this General Privacy Notice, different privacy notices may apply to you depending on your relationship with General Atlantic and location. If you are an investor or prospective investor in GA funds, you will be subject to our Limited Partner Privacy Notice. If you are an employee, you will be subject to our Employee Privacy Notice. If you are a job applicant or included in our Global Talent Bank, you will be subject to our Applicant Tracking Privacy Notice. If you are based in California, please refer to the California Notice of Collection below.

About Us

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, but not limited to, the General Data Protection Regulation 2016/679 (“GDPR”), the UK Data Protection Act, the California Consumer Privacy Act of 2018 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, or when you interact with us at conferences, meetings, events, our office or your office, or otherwise in other public places, 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), CCTV footage, 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, our affiliates or our portfolio companies.

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 or inferences we make from meetings with you (“Sensitive Personal Data”).

Further, when you use our Website, we may (ourselves or through a third-party vendor) automatically gather information about your devices and usage of the Website, such as your IP address, identifies associated with your device, browser and device characteristics, website preferences, information regarding websites accessed immediately before and after you visit the Website, the date and time of your visit to the Website, and information about how you navigate the Website. GA collects this information by using cookies, web pixels and other similar automated technologies (collectively, “Tools”). We use this information to better understand, customer and improve the user experience with our Website and our services. For more information about these Tools, please see our Cookie Policy.

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. directly or indirectly through this Website, when you contact us via email or provide us with a business card, or when you invest in one of our investment funds); 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.

In addition, when you use the Website, we may (ourselves or through a third party vendor) automatically gather information regarding websites accessed immediately before and after your visit to our Website. We collect this information by using “cookies”, web pixels, and other similar automated technology. We use this information to better understand, customize and improve the user experience.

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 investment advisory services and information (in which case, you should also refer to the Limited Partner Privacy Notice);
  • 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 (in which case, you should also refer to the Limited Partner Privacy Notice);
  • to establish and manage our business relationships;
  • to send you newsletters or other marketing or promotional materials;
  • to send you information on news, publications, seminars and events;
  • to communicate with you (including to answer questions you may have) and improve our services and communications to you;
  • for the purposes of employment, partnership or the supply or retention of services (in which case, you should also refer to the Applicant Tracking Privacy Notice and/or the Employee Privacy Notice);
  • to process your requests of, and applications to, us (in which case, you should also refer to the Applicant Tracking Privacy Notice);
  • to consider you for potential roles, opportunities or jobs at General Atlantic, or one or more of its portfolio companies or investment prospects (in which case, you should also refer to the Applicant Tracking Privacy Notice);
  • to share contact details and other information to facilitate introductions with General Atlantic portfolio companies and investment prospects (in which case, you should also refer to the Applicant Tracking Privacy Notice);
  • to comply with local laws and regulations or 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;
  • to analyze your personal data internally;
  • ·or insurance purposes;
  • to send you invoices or reminder notices;
  • to personalize your experience with us, including on our Website;
  • to perform analytics (including market research, trend analysis and anonymization of personali information);
  • to operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our Website, products and services; developing new products and services; managing and evaluating the effectiveness of our communications; and performing other internal functions);
  • protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • for any other purpose for which this information was provided to us or for any purpose related or ancillary to any of the above.

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

We will use the personal data we collect from you only for the purposes described herein or for purposes that we explain to you at the time we collect your personal data. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to

you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) in accordance with any applicable data protection laws, acts or regulations.

In general, we will process your personal data to carry out our legitimate business interests, where such interests do not override your fundamental rights and liberties. Where required, we will ask you to provide your consent for specific types of personal data (e.g. special categories of personal data). We may also be required to process your personal data in order to comply with local laws and regulations, for example where we are required to disclose certain information to the local authorities.

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. Where we are relying on legitimate interest, we have documented legitimate interest assessments. 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. We use your personal information to send direct marketing materials only where you have provided your consent or otherwise when we are permitted by applicable law to do so.

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, to pay for services, analytics providers, 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 Privacy 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 Privacy 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 and/or the UK as well as within it.

You should be aware that in territories outside the EEA and the UK, 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 and the UK.

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 You Have?

Depending on your jurisdiction you may have some or all of the rights listed below. For example, under the GDPR and the UK Data Protection Act, residents domiciled in the EU, EEA or the UK have certain rights with respect to their personal information. In particular, EU, EEA, and UK residents 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, or call our toll-free number at (844) 470-0002 to exercise your rights.

If you do not want to have a profile in GA’s Global Talent Bank, or want us to stop contacting you about business opportunities, you can let us know at any time by emailing us at privacy@generalatlantic.com. We will remove your details and add you to a list so make sure that you are not contacted about opportunities in the future.

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 Privacy 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 backup archives), we will store your personal data securely and isolate it from further processing until deletion is possible.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy 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 Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

How to contact us

If you have any questions or concerns concerning this Privacy Notice or the way we process your personal data, please contact us at:

Email: privacy@generalatlantic.com

Call: (844) 470-0002; and

Mail: General Atlantic Service Company, L.P., Park Avenue Plaza, 55 East 52nd Street, 33rd 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).

Anonymous Hotline: via Lighthouse Okta tile

Complaints

If you wish to make a complaint about how we have handled your personal information, please contact us at the details above 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.

California Notice of Collection

Collection:

Within the past twelve (12) we have collected the follow categories of personal information:

  • Identifiers, such as a real name, alias, postal address, unique personal identifier, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
  • Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information, such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
  • Internet or other similar network activity, such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Geolocation data, such as physical location or movements.
  • Sensory data, such as audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information, such as current or past job history

We also collect Sensitive Personal Information, including personal information that reveals:

  • A consumer’s social security, driver’s license, state identification card, or passport number.
  • A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
  • A consumer’s precise geolocation.
  • A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
  • The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication.

Please note Sensitive personal information that is “publicly available” shall not be considered sensitive personal information or personal information.

How we use your personal information

We may use personal information about you:

  • to provide you with our investment advisory services and information (in which case, you should also refer to the Limited Partner Privacy Notice);
  • 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 (in which case, you should also refer to the Limited Partner Privacy Notice);
  • to establish and manage our business relationships;
  • to send you newsletters or other marketing or promotional materials;
  • to send you information on news, publications, seminars and events;
  • to communicate with you (including to answer questions you may have) and improve our services and communications to you;
  • for the purposes of employment, partnership or the supply or retention of services (in which case, you should also refer to the Applicant Tracking Privacy Notice and/or the Employee Privacy Notice);
  • to process your requests of, and applications to, us (in which case, you should also refer to the Applicant Tracking Privacy Notice);
  • to consider you for potential roles, opportunities or jobs at General Atlantic, or one or more of its portfolio companies or investment prospects (in which case, you should also refer to the Applicant Tracking Privacy Notice);
  • to share contact details and other information to facilitate introductions with General Atlantic portfolio companies and investment prospects (in which case, you should also refer to the Applicant Tracking Privacy Notice);
  • to comply with local laws and regulations or 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;
  • to analyze your personal data internally;
  • for insurance purposes;
  • to send you invoices or reminder notices;
  • to personalize your experience with us, including on our Website;
  • to perform analytics (including market research, trend analysis and anonymization of personali information);
  • to operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our Website, products and services; developing new products and services; managing and evaluating the effectiveness of our communications; and performing other internal functions);
  • protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • for any other purpose for which this information was provided to us or for any purpose related or ancillary to any of the above.

We do not sell your personal information and have not done so within the past twelve (12) months. We only share personal information in limited circumstances. Within the past twelve months we have shared information about your Internet or other similar network activity with third parties that support the cookies used on our website, including Google Analytics. For more information about our use of cookies, and how you may restrict their use please refer to our Cookie Policy.

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 Privacy 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 backup archives), we will store your personal data securely and isolate it from further processing until deletion is possible.

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:

  • Request that we disclose, free of charge, the categories and specifics of the personal information we collect about California residents (and/or, if applicable, sell, share, or otherwise disclose to a third party for business purposes).
  • Choose to opt-out of the sale or sharing of personal information. Currently, however, General Atlantic does not sell personal information. General Atlantic only shares personal information (as sharing is defined under Cal Civil Code Section 798.140 (ah) (1)) that concerns internet or other similar network activity. You may opt-out of this sharing by changing the preferences in your browser. For additional information about how we collect and share this information please refer to our Cookie Policy.
  • Choose to limit the use of your sensitive personal information, under certain circumstances.
  • Request that we correct any inaccurate personal information we possess concerning California residents.
  • 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 note that the rights under the CCPA do not apply to Personal Information collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act (Public Law 106-102) and Fair Credit Reporting Act (12 CFR 1022). Please email us at privacy@generalatlantic.com, or call our toll-free number at (844) 470-0002 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.