Commitment to Privacy
GrowthCurveCapital, LP, a Delaware limited partnership (Delaware State file number: 4101087)and its affiliates (collectively “GCC,” “we,” “us” or “our”) are committed to responsibly handling personal information  that we collect or otherwise process regarding our investors (including, for the purposes hereof, a potential investor or former investor) and individuals who visit our website (the “Website”) or otherwise communicate or engage with us (“you” or “your”).
Collection of Personal Information
The types of personal information collected by or on behalf of GCC about you varies based on GCC’s interactions with you (for example, whether you are an investor or an individual visiting the Website).
Personal information collected by or on behalf of GCC about individuals visiting the Website is obtained directly from you or certain third parties. The personal information we collect about you in the course of your interaction and correspondence with the Website includes, but is not limited to, the following:
· IP address and other online identifiers/web beacons;
· details of your online browsing activities on the Website, including, but not limited to, the full Uniform Resource Locators (URL), clickstream to, through and from the site (including, but not limited to, date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs),and methods used to browse away from the page;
· your browser type and version, relevant plug-ins, operating system and platform;
· your time zone settings; and
· in relation to any personal account you create on the Website (if such functionality becomes available on or through the Website):
o user names, passwords and other log-in information;
o your account settings, including, but not limited to, any default preferences;
o a log of your browsing activities during your visit to the Website; and
o any preferences we have observed, such as the types of products that interest you, or the areas of the Website that you visit.
If you are an investor, additional personal information collected by or on behalf of GCC about you is obtained directly from you, your professional advisors or other third parties, and generally comes from subscription agreements, investor questionnaires, other required forms, documents and agreements or other correspondence (including, but not limited to, written, telephone, video conference or electronic contacts) with you regarding your accounts or transactions with non-affiliated third parties. The personal information we collect about you as an investor in the course of your interaction and correspondence with GCC and its representatives includes, but is not limited to, the following:
· basic personal details, including, but not limited to, your name and address (and proof of name and address), email address, telephone number, any other contact details you may supply, social security number, tax details, nationality, citizenship, tax residency, date of birth, and family connections;
· details of your company’s directors, shareholders, secretaries, authorized signatories and other comparable officers and/or beneficiaries, and identification documents;
· financial information, including, for example, banking details;
· information regarding your assets and/or income and/or financial dealings, including, for example, net worth and investment history;
· personal characteristics, including, for example, your signature and physical characteristics or description;
· details of business advisers you may employ, including, for example, wealth manager sand independent financial advisers; and/or
· records of all communications, including, for example, recordings of your attendance(or your representative’s attendance) at certain meetings/phone calls, and electronic communications with GCC staff and meeting notes (see below for more details).
If you are an investor, GCC also may collect or receive personal information about you from third parties such as service providers to GCC’s sponsored funds, investor advisors (including, but not limited to, independent financial advisors), vendors, and publicly available sources such as company websites. We may collect or receive any of the personal information noted above from such third parties, and in addition, we may collect or receive the following:
· details of any complaints made by you with respect to your dealings with the relevant service provider to the fund;
· data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks); and/or
· fraud inquiries (for example, information from police reports).
In addition, if you are an investor, GCC obtains personal information about your interests in funds (such as capital account balances and percentage interests)from the funds themselves and their other non-affiliated service providers.
The Website is not intended for children and we do not knowingly collect data relating to children(including any minors under the age of 16).
Use of Information Collected
GCC uses your personal information to operate its business, including as follows:
· to provide you with services that you have requested and to fulfill GCC’s contractual obligations, including, but not limited to, any contractual obligations as the general partner(s) and/or the investment advisor to a fund in which you have subscribed;
· too perate the Website and our other IT systems, and safeguard their security;
· to fulfill our contractual obligations to other third parties to whom you have provided your information;
· for GCC’s internal business administration and record keeping purposes;
· for legal and regulatory compliance purposes, including, for example, as necessary to respond to governmental, regulatory or law enforcement agency requests;
· where required or considered appropriate, including, for example, prior to admitting you to a fund, prior to accepting capital contributions or making a capital distribution, carrying out “know-your-client” (KYC) checks and other procedures that GCC undertakes in the course of GCC’s ongoing business relationship with you; and/or
- provide information, on a need to know basis, to future purchasers or merger partners of all or a portion of GCC or any of its funds;
GCC generally does not send marketing messages; however, from time to time, GCC will provide you with information on GCC-sponsored funds that we may be raising. You have the right to ask us not to send you marketing messages by post, telephone or e-mail or any combination of these at any time; however you acknowledge that such information may be included in general update letters and while you may choose not to receive such updates, we are under no obligation to provide redacted versions of such letters or otherwise create separate report son your behalf excluding such marketing information. You can also let us know at any time that you wish to change your mind and to start receiving such messages. You can do this by replying directly to the marketing message or at any time by contacting us.
Disclosure of Personal Information
· vendors and service providers needed to operate the Website, and the fund(s) associated with you, including, but not limited to: (i) legal counsel, (ii) accountants,(iii) audit firms, (iv) banks, (v) administrators, (vi) tax consultants, (vii) tax preparers, (viii) placement agents, (ix) financial advisors, (x) broker-dealers, (xi) transfer agents, (xii) custodians, (xiii)persons or entities that are assessing our compliance with industry standards, and (xiv) vendors supporting the Website or our other IT systems;
· law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including, for example, the U.S. Securities and Exchange Commission) or of other countries with whom a fund (or a fund’s portfolio company) transacts who request or require such information in order to issue business or regulatory licenses or permits; and
· third parties with whom a fund (or a fund’s portfolio company) transacts who require information to comply with local anti-money laundering laws, including, but not limited to, banks and other financing counter parties.
In addition, we may disclose personal information as follows:
· to law enforcement agencies and regulators, government agencies or departments or competent authorities of the U.S. (including, for example, the U.S. Securities and Exchange Commission) or of other countries, where we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary or advisable to help prevent or detect fraud or other crimes or to protect our rights, property, or safety, or that of our clients, investors or others. Such disclosure (including, but not limited to, tax status, identity or residency or other personal or payment information, documents or self-certifications) may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
· if we are under a duty to disclose or share your personal information with tax authorities, such information requested by such tax authorities, who may transfer such information to the government or the tax authorities in another country where you may be subject to tax. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or service providers who may make such filings or disclosures on our behalf;
· subject to any contractual confidentiality obligations, we may disclose investor names, participation on any limited partner advisory committee, jurisdiction of the investor and/or commitment size to other limited partners or prospective investors of a GCC-sponsored fund;
· if you use a financial or other adviser (as indicated on your subscription agreement or subsequently communicated to us), the details of your investments and valuations may also be provided to such adviser(s); and/or
· on a need to know basis to future purchasers or merger partners for due diligence purposes.
For clarity, GrowthCurve Capital LP and its affiliates (including, but not limited to, any GCC-sponsored funds) also share personal information amongst themselves.
We do not sell or offer to sell any personal information about you to third parties.
We acknowledge that the personal information you provide may be confidential, and we maintain policies and procedures designed to maintain the confidentiality of and protect your personal information in accordance with our normal procedures and applicable law. We maintain physical, electronic, and administrative measures designed to safeguard your personal information and prevent unauthorized access thereto.
Unfortunately, the storage and transmission of electronic information is not completely secure. Although we strive to protect your personal information, we cannot guarantee the security of information stored on our or our vendors’ servers or transmitted via email or through the Website; you transmit personal information to us at your own risk. In addition, links on the Website may take you to third-party websites over which we have no control. While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
Two types of cookies may be used on the Website – “session cookies” and “persistent cookies.” Session cookies are temporary cookies that remain on your device until you leave the Website. A persistent cookie remains on your device for much longer or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings).
What are Cookies?
Cookies are files or pieces of information that maybe stored on your computer (or other internet-enabled devices, such as a smartphone or tablet) when you visit the Website. A cookie will usually contain the name of the website from which the cookie has come from, the “lifetime” of the cookie (i.e., how long it will remain on your device) and a value, which is usually a randomly generated unique number.
Most internet browsers are initially set up to automatically accept cookies. You can change the settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you disable the cookies that we use, this may impact your experience while on the Website. For example, you may not be able to visit certain areas of the Website.
If you use different devices to view and access the Website (e.g., your computer, smartphone, tablet), you will need to ensure that each browser on each device is adjusted to suit your cookie preferences.
If you would like more information about cookies, we can recommend www.aboutcookies.org and www.allaboutcookies.org as helpful resources. Both websites also provide instructions on how to reject cookies if you would like to do so.
The information below summarizes the different types of cookies we currently use on theWebsite, together with their respective purpose and duration (i.e., how long each cookie will remain on your device):
Type of Cookie
Performance / Analytical Cookies
What do they do?
Cookies that help us understand how visitors interact with our web properties by providing information about the areas visited, the time spent on the Website and any issues encountered, such as error messages. They help us improve the performance of the Website, alert of any concerns and more.
Do these cookies collect my personal information/identify me?
These cookies do not identify you as an individual. All data is collected and aggregated anonymously. To opt out of the aggregation and analysis of data collected about you on the Website by Google Analytics, visit https://tools.google.com/
dlpage/gaoptoutand download and install the Google Analytics Opt-out
ThePerformance / Analytical cookies used on the Website include:
- Name of Cookie: _ ga
First / Third Party: First
Purpose: Used to distinguish users
- Name of Cookie: _ gid
First / Third Party: First
Purpose: Used to distinguish users
- Name of Cookie: _ gat_gtag_UA_2563069_13
First / Third Party: First
Purpose: Used to throttle request rate
- Name of Cookie: AMP_TOKEN
First / Third Party: First
Purpose: Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
Google may adjust their cookies from time to time. Please visit https://developers.google.com/
cookie-usage#analyticsjs to review their latest cookie details.
Additional Information for Individuals Whose Personal Data is Subject to the GDPR or the UK GDPR
For the purposes of applicable data privacy legislation, GCC is a “controller” of EEA/UK Residents’ personal data. We may transfer, use, store and/or otherwise process your personal data outside of the EEA or the UK, primarily in the U.S., and the laws of the U.S. and certain other destination countries may not offer the same standard of protection for personal data as countries within the EEA or UK. EEA/UK Residents’ personal data also may be processed by staff operating outside the EEA or UK who work for us or for one of our vendors (for example, those who supply support services to us).
1. Our bases for collecting and using personal data
· the use of personal data is necessary for the performance of a contract with you for provision of our products and/or services (including, for example, fund subscription agreements and fund limited partnership agreements) or to take steps at your request prior to entering into such a contract;
· we have legal obligations that we have to discharge (including, for example, legal obligations set forth in fund limited partnership agreements, investment advisory agreements and other operative documents);
· the use of your personal data is necessary for our legitimate interests (including, for example, in marketing to prospective investors for the fund in which you are invested, successor funds or other GCC-sponsored funds);
· you have consented to such use; and/or
· to establish, exercise or defend our legal rights for the purposes of legal proceedings.
We do not expect to process “sensitive” or “special” categories of personal data under the GDPR or UK GDPR;however, if we were to process such personal data, we would do so only where we have asked for your explicit consent, or otherwise where this is necessary for the establishment, exercise or defense of legal claims, or as otherwise may be permitted under applicable laws.
Provision of certain of your personal data is a legal and contractual requirement necessary to becoming an investor in any GCC-sponsored fund or other pooled vehicle. If you choose not to provide such personal data, we may not be able to perform some of the tasks we need to in order to provide certain products or services to you. If you choose to provide your consent with respect to certain processing of your personal data, you can withdraw it at any time by contacting us.
2. Retention of personal data
We will keep your personal data only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal data are available in our retention policy, which you can request by contacting us. When determining the relevant retention periods, we take into account factors, including, but not limited to, the following:
· our contractual and business relationships with you;
· legal obligations under applicable law to retain personal data for a certain period of time;
· statute of limitations under applicable law;
· (potential) disputes; and
· guidelines issued by relevant supervisory authorities.
3. Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
· request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully;
· request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected;
· object to processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also may have the right to object where we are processing your personal data for direct marketing purposes;
· request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see above);
· request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and/or
· request the transfer of your personal data to another party in a machine-readable, commonly used and structured format.
We will respond to your request within one month of receipt of your request. In some cases, we may not be able to fulfil your request to exercise the right before this date, and may need to request more time. Where we cannot provide a full response to you for any reason, we will let you know about this in our initial reply to your request.
4. Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current.Please keep us informed if your personal data changes during your working relationship with us.
You will not have to pay a fee to access your personal data (or to exercise any of the other above-listed rights). In some cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.
6. Wha twe may need from you
To access your personal data (or to exercise any of the other above-listed rights), we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal data (or to exercise any of your other above-listed rights). This is another appropriate security measure designed to ensure that personal data is not disclosed to any person who has no right to receive it.
7. Right to complain
global/contact-us/ or 0303 123 1113.
Additional Information for Individuals Whose Personal Information isSubject to the CCPA
Residents of the state of California have certain rights with respect to their personal informationpursuant to the California Consumer Privacy Act of 2018 (“CCPA”) as further described in this section. Please note that the rights under the CCPA do not apply to personal information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act (Public Law 106-102), the Fair Credit ReportingAct (12 CFR 1022) and/or the California Financial Information Privacy Act.Nor do the rights set forth below in this section apply to (i) GCC personnel or job applicants seeking opportunities at GCC or (ii) personnel working on behalf of business partners with whom we are conducting business.
Under certain circumstances, under the CCPA you may have the right to:
- request that we disclose, free of charge, the categories and specific pieces of personal information we collect about you (and, if applicable, sell or otherwise disclose to a third party and the categories of such third parties), the sources from which such personal information was collected, and the business purpose for collecting, selling or disclosing such personal information;
- choose to opt out of the sale of your personal information. Currently, we do not sell your personal information; and
- request that we delete the personal information we have collected about you.
We will not discriminate against any California resident who exercises the rights set forth in this section.
These rights are not absolute and each is subject to certain exceptions or qualifications. For example, if you are currently an investor in one of our funds and you request that we delete the personal information we have collected about you, the CCPA permits us to deny such request and retain your personal information to the extent necessary to manage the applicable fund and our business relationship with you in connection with that fund.
By post: 450 Lexington Avenue, Suite 817, New York, NY 10017
By phone: 212-970-1900
By email: email@example.com
 For the purposes of this section, “personal data” has the meaning given to such term in the GDPR or UK GDPR, as applicable.[
 “Special” or “sensitive” categories of personal data include, among other things, data concerning your health, revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or concerning your sexual orientation.
 For the purposes of this section, “personal information” has the meaning given to such term in the CCPA.
Last updated: May 24, 2021