Effective as of September 2023

At General Atlantic, we are committed to handling personal information about you responsibly  and in accordance with applicable data protection laws. 

This Notice of Privacy Policy & Practices (this “Privacy Notice”) describes the types of personal  information we collect about you, how we may use that personal 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 contact us to answer any questions you may have about our privacy  practices.

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 (together with our subsidiaries and  affiliates, “GA”). GA has a number of subsidiaries and establishments located in various  jurisdictions, including, but not limited to, in the United Kingdom and the European Union, details  of which can be found on the GA website at https://www.generalatlantic.com/contact-us/ (collectively, the “Firm”, “we”, “us” or “our”). This notice applies to information provided to any of  GA’s subsidiaries, affiliates, entities or offices around the world.

We are a data controller for the purposes of the applicable privacy laws in the jurisdictions in  which we operate. More specifically, in case of a partnership based in Luxembourg, the general  partner acting on behalf of the relevant partnership will be acting as data controller. This means  in relation to the personal information you provide to us, we will determine why and how it is used.

What We Collect

We may collect your “personal information” during the course of  our relationship with you.

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

Examples of personal information processed by GA includes the following types of data: your name, age, gender, address, phone number, fax number, email and postal address, date of birth, social security/national insurance (or other similar) identification number, passport number, identity card with photo, profession, proof of address, tax identification number, tax status, tax certificates and other related tax information, citizenship, nationality, country location and financial and credit information, including but not limited to IBAN and BIC codes, capital account balance and bank account information, commitment amount, portfolio information and participation in other investments, assets and investment history with funds sponsored by GA, income, source of wealth, source of funds, politically exposed person status, power of attorney, sanction status, related parties and client communications via electronic or other means.

We may also collect “sensitive personal information”, which is a subset of personal information concerning racial or ethnic origin, political opinions, religious beliefs or trade union memberships. In addition, GA may process sensitive personal information such as criminal convictions and offenses, as well as political opinions for AML/KYC purposes, background checks or management assessments (if applicable). In such context, your political opinions which have public exposure will be processed by GA on the basis of the personal data having been made public by you and/or the personal information is necessary for reasons of substantial public interests or otherwise as permitted by law. All of the above categories of data are collectively hereinafter referred to as “Personal Information”.

California Residents: Our Notice of Collection specific to California Residents is available on our website (www.generalatlantic.com).

How we Collect Personal Information

We collect Personal Information about you from the following sources:

• Information we receive directly from you through investor questionnaires, investor data sheets, tax documents and certifications, agreements, correspondence and other forms of communication (written, telephonic or electronic), which may include your name, address and other contact details, social security/national insurance (or other similar) identification number, tax identification and related tax information, citizenship, country location, bank account number, income, assets, investment history with the Firm and other personal financial data.
• Information about your transactions with us, our affiliates or non-affiliated third parties, such as your capital account balance, other account data, portfolio information, and participation in other investments.
• Information we receive from third parties to supplement information provided by you, which is obtained by us or by the third parties from reviewing publicly available data and resources. Such information may also include “sensitive personal information” as described in “What we Collect” above, prior business dealings and details about your source of funds.

Please note that we require this Personal Information in order to provide our services to you, to offer you new products or services, to offer you potential employment or consulting opportunities, or to inform our decision on whether it is permissible, under applicable laws and regulations, to accept or continue to accept capital from you or your affiliated entities. If you do not provide such Personal Information we may not be able to provide you with all of the services you have requested or meet our legal or regulatory obligations.

Use of Personal Information

We may use Personal Information about you to:

• (i) provide investment management and advisory services to you, (ii) make investments in securities pursuant to one or more of GA’s investment programs, including, but not limited to, (x) GA’s Core Program, as described in the Confidential Private Placement Memorandum of GA’s Core Program (as revised from time to time), (y) GA’s companion funds and continuation vehicles and (z) investment funds and managed accounts that we advise under our “GA Credit” platform (x, y and z collectively, our “Product Offerings”), (iii) call capital from and distribute capital to you or your affiliated entities and/or (iv) report on the performance of the investments held (directly or indirectly) by you or your affiliated entities;
• maintain the books and records of any fund sponsored by GA or any register of investors;
• process subscription agreements and payments of distributions to investors;
• manage investor capital and other accounts;
• file mandatory registration with registers including, among others, any register of beneficial owners;
• comply with, or obtain the benefit of, any laws and regulations applicable to GA or its investments, including but not limited to “know your customer” obligations based on applicable anti-money laundering and anti-terrorist requirements, economic and trade sanctions, customer due diligence, suspicious activity reporting, and other applicable laws, regulations, ordinances and obligations;
• respond to any subpoena or other legal process or in connection with any litigation to which we are a party (unless prohibited by applicable law, regulation or order) or comply with court or administrative orders and/or otherwise defend our legal rights;
• for tax purposes, including reporting to and/or being audited by national and tax or regulatory authorities (including laws and regulations relating to the U.S. Foreign Accounts Tax Compliance Act or the Common Reporting Standard);
• make introductions to other investors, investment prospects, portfolio companies or other third parties;
• send you marketing materials and firm updates and notices, whether about existing or new Product Offerings or otherwise (where we have received your consent to do so, or we believe that you may be interested in the material as it relates to existing or new Product Offerings);
• manage risks applicable to GA or its investments;
• allow due diligence to be carried out by any third party that acquires, or is interested in acquiring or securitizing, all or part of GA’s assets, or that succeeds to it in carrying on all or a part of its businesses, or services provided to it, whether by merger, acquisition, reorganization or otherwise; and
• process Personal Information of employees or other representatives of investors which are legal persons.

Legal Basis for Processing

There is a need to process Personal Information for the purposes set out in this Privacy Notice, in certain cases, as a matter of contractual necessity under or in connection with your applicable subscription agreement with GA, and/or in the legitimate interests of GA to operate our businesses. From time to time, we also may need to process the Personal Information on other legal bases, including to comply with legal obligations or to protect the interests of investors in a fund sponsored by GA or other parties, or if it is necessary for a task being carried out in the public interest. For the purposes listed above, General Atlantic is relying on performance of a contract necessity and legitimate interests. For the instances of legitimate interest, we have documented legitimate interest assessments.

We will only process your Personal Information where:

• you have given your consent to such processing, and you may withdraw this consent at any time by emailing [email protected];
• the processing is necessary to provide our services (as detailed above) to you compliant with our contractual obligations (please see “Use of Personal Information” clauses (a), (c), (d) and (l) above);
• the processing is necessary for compliance with our legal or regulatory obligations (please see “Use of Personal Information” clauses (b), (e), (f), (h) and (l) above); and/or
• the processing is necessary for our legitimate business interests or those of any third-party recipients that receive your Personal Information (please see “Use of Personal Information” clauses (f), (g), (j), (k), (l) and (m) above).

See “Use of Personal Information” above and “Disclosure of Personal Information” below for additional information.

Disclosure of Personal Information

We will not disclose your Personal Information to third parties unless:

• As authorized – if you request or authorize the disclosure of the information;
• As necessary to provide services to you – for example, sharing information with companies that help us provide the services to you (as described below) and/or third parties that process or maintain information on their databases or systems to help us provide the services to you, as described above; and/or
• As required by law – for example, (i) as part of a regulatory or similar filing obligation with applicable authorities, regulators and/or supervisory governmental agencies, as well as national registers including tax authorities, or in order to provide us with information, advice or services to help ensure our compliance with applicable laws or regulations, or (ii) in response to any subpoena or other legal process or in connection with any litigation to which we are a party (unless prohibited by applicable law, rule or order).

Categories of Third Parties to Whom Personal Information is Disclosed

We may disclose Personal Information about you to our affiliates, attorneys, auditors, accountants, any alternative investment fund manager, consultants, any depositary, lenders, transfer agents and other non-affiliated third-party service providers that provide services or advice in relation to our investment product offerings (the “Recipients”). Personal information will be disclosed where it is necessary to do so in order to service your account, including to call capital, borrow capital, distribute capital, process transactions, maintain accounts, report on the performance of your account, provide tax related information or documentation, ensure compliance with applicable laws or regulations, or where disclosure is in our legitimate business interests, for example, to respond to court orders or legal investigations.

We may also disclose Personal Information about you to any prospective buyer in the event that we sell any part of our business or assets, or to any third party to whom we assign or novate any of our rights or obligations.

The Recipients may under their own responsibility disclose the Personal Information to their agents and/or delegates (the “Sub- Recipients”), which shall process the Personal Information for the sole purpose of assisting the Recipients in providing their services to GA and/or assisting the Recipients in fulfilling their own legal obligations.

The Recipients and the Sub-Recipients may, as the case may be, process the Personal Information as data processors (when processing the Personal Information on behalf and upon the instructions of GA and/or the Recipients) or as data controllers (when processing the Personal Information for their own purposes, namely fulfilling their own legal obligations).

The Personal Information may also be disclosed in particular to tax authorities, which in turn may act as data controller and disclose the Personal Information to foreign tax authorities.

International Transfers

GA operates a global business and may transfer your Personal Information to our subsidiaries and affiliates located in a country other than the country in which your Personal Information was collected.

Please be aware that some countries may not offer the same level of protection as the country in which your Personal Information was collected, however, the collection, storage and use of your Personal Information will continue to be governed by this Privacy Notice.

Where the Recipients and Sub-Recipients are located in a country outside the European Economic Area (“EEA”) that benefits from an adequacy decision of the European Commission (such as the United Kingdom), Personal Information shall be transferred to the Recipients and Sub-Recipients upon such adequacy decision. Where the Recipients and Sub-Recipients are located outside the EEA in a country which does not ensure an adequate level of protection for Personal Information or does not benefit from an adequacy decision of the European Commission (such as the United States and India), the data controller will have entered into legally binding transfer agreements with the relevant Recipients in the form of the European Commission-approved model clauses or any other appropriate safeguards pursuant to the GDPR (as defined below), as well as, if necessary, supplementary measures.

The Firm will also ensure that any transfers of your personal data outside of the country in which it was collected complies at all times with applicable privacy laws. To find out more about the safeguards the Firm has in place to protect your Personal Information please contact us as [email protected].

Security of Personal Information

We restrict access to your Personal Information to those employees or service providers who need to know such information to provide services to you. We maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard your Personal Information against loss, misuse or unauthorized access, disclosure, alteration or destruction. These include firewall protection, anti-virus software and encryption of data. Physically, our staff are instructed on how to handle your Personal Information, including keeping such information in secure locations (such as locked rooms and/or cabinets). Access to our premises is restricted to those with valid electronic access cards and/or keys.

All records and files maintained by us, including client information, are confidential and remain the property of the Firm. Password protections limit access to computers, voicemail and email systems. Records and files are not disclosed to any outside party without our express permission.

Confidential information obtained during or through employment with GA may not be used by any GA employee for the purpose of furthering current or future outside employment or activities or for obtaining personal gain or profit. We reserve the right to avail ourselves of all legal or equitable remedies to prevent impermissible use of confidential information or to recover damages incurred as a result of the impermissible use of confidential information.

When information about our clients is disclosed to non-affiliated third parties, we require that the third party maintain the confidentiality of the information disclosed and limit the use of information by the third party solely to the purposes for which the information is disclosed or as otherwise required by law.

How long we retain your Personal Information

We will retain your Personal Information for so long as you are a current investor in any fund sponsored by GA and thereafter for a period of ten (10) years, unless longer or shorter statutory limitation periods apply. In some circumstances, the Personal Information may be anonymized so that it can no longer be associated with you, in which case it is no longer Personal Information and can be kept for an unlimited period of time. Once GA no longer requires the Personal Information for the purposes for which it was obtained, it will securely destroy the Personal Information in accordance with any applicable laws, regulations, rules or internal policy requirements.

Automated Decision Making and Profiling

We do not use computer algorithms or profiling to make automated decisions based on your Personal Information.

Personal Information Rights for EU and EEA Residents

In accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”) and any applicable national data protection laws (including but not limited to the Luxembourg law of 1st August 2018 organizing the National Commission for data protection and the general system on data protection, as amended from time to time), the UK’s Data Protection Act of 2018 (“DPA”) and the Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector (each as amended or replaced from time to time, collectively referred herein as the “Data Protection Laws”), the general partners of alternative investment funds sponsored by GA and based in Luxembourg may act as a data controller and collect, store, and process by electronic or other means the data supplied by investors and/or prospective investors (or if the investor and/or prospective investor is a legal person, any natural person related to it such as its contact person(s), employee(s), trustee(s), nominee(s), agent(s), representative(s) and/or beneficial owner(s)) (together the “Data Subjects”, individually the “Data Subject”, “you” or “your”) at the time of their subscription for the purposes outlined in the present Notice of Privacy Policy.

Investors and/or prospective investors who are legal persons undertake and guarantee to process Personal Information and to supply such Personal Information to GA in compliance with the Data Protection Laws, including, where appropriate, informing the relevant Data Subjects of the contents of this section, in accordance with Articles 12, 13 and/or 14 of the GDPR.

Under the conditions and limitations set forth by the Data Protection Laws, Data Subjects domiciled in the UK, 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 Information 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.

If you would like to exercise any of your rights in relation to our processing of your data, please contact us at the details below.

Personal Information Rights for California Residents

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 or otherwise disclose to a third party for business purposes). This includes the categories of sources from which information is collected, the purpose of collection, selling or sharing, and categories of third parties to whom personal information has been disclosed, Please note that a disclosure request may only be made twice within a twelve month period;
• Choose to opt out of the sale or sharing of Personal Information. Currently, however, General Atlantic does not sell or share Personal Information as defined under Cal Civil Code Section 798.140 (ah) (1);
• Request the correction of any inaccurate personal information we collect and maintain;
• 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; and
• Request that we limit the use of your sensitive personal information. Please note this right shall only apply in limited circumstances, where sensitive data has been used for purposes other than those set forth in section 7027(m).

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

If you would like to exercise any of your rights in relation to our processing of your data, please contact us at [email protected] or by calling (844) 470-0002. In order to comply with your request, you may need to provide us with personal information and other information to verify your identity and the nature of your request. Please note that in some circumstances, we may not be able to fully comply with your request, for example, if we are required to retain certain information about you to comply with applicable laws and regulations or if the information is necessary in order for us to provide the services you requested.

You have the right to appoint an authorized agent to exercise your rights on your behalf.

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).

Complaints

If you wish to raise 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 or in Luxembourg is with the Commission Nationale pour la Protection des Données at the following address: 15, Boulevard du Jazz, L-4370 Belvaux, Grand Duchy of Luxembourg.

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: [email protected]
• If based outside the EEA, by calling: (844) 470 0002
• If based outside the EEA, by mailing: 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 establishment in your home country). For further information see https://www.generalatlantic.com/contact-us/

Please note that GA does not have a data protection officer and is not required by law to have one.

We will adhere to the policies and practices described in this this Privacy Notice regardless of whether you continue to hold an equity interest in an investment entity managed by GA.

We reserve the right to change these policies and practices at any time. If appropriate, a revised Privacy Notice incorporating such changes will be provided to you.