Privacy Notice

GTIS Partners collects and processes Personal Data (which we define below) about you from your use of this website and through other means, such as by contacting us directly by phone or email or more generally in the course of operating our business. This Privacy Notice explains how we collect Personal Data, how we use your Personal Data and how you can assert your rights in accordance with applicable data protection laws. This Privacy Notice does not address our privacy practices with respect to any Personal Data we may collect from an investor in the funds that we sponsor or manage. We address these practices in separate notices to investors.

1. What is Personal Data and what Personal Data do we collect?

“Personal Data” is any information relating to you or that we can otherwise link to you.

The Personal Data we collect on this website may include your name, email address, residential address, IP address, login information for our investor portal and other contact information. Some of this information we will only have access to if you provide it to us. When you visit our website, we may collect information about you when you enter and browse our website through the use of “cookies,” web server logs and other electronic tools. This information may include, without limitation, the number and frequency of your visits to our website, the websites accessed before and after you visit our website, the internet browser used by you and your IP address.

In addition to Personal Data collected from your use of our website, we may also collect Personal Data regarding our business contacts, current and prospective investors, vendors and other contacts. We will collect some of this Personal Data if you contact our office or employees directly.

2. How do we collect Personal Data?

We collect Personal Data that you voluntarily provide to us, such as through “contact us” forms you choose to submit on our website to obtain more information about GTIS Partners or our funds. We may also collect Personal Data through the use of “cookies” on our website, in the ordinary course of evaluating service providers, vendors and investments, in marketing our funds or from publicly available or accessible directories, databases and agencies.

3. How do we use your Personal Data?

We use the Personal Data we collect from you on our website for communication purposes, such as, but not limited to (i) sending you information about GTIS Partners and/or our investment funds and (ii) maintaining our list of contacts. We use the Personal Data we collect from you through other means for business purposes, such as, but not limited to (i) communicating with service providers and vendors and (ii) researching investment opportunities.

4. Why do we process your Personal Data?

We process your Personal Data collected from your use of this website for certain business reasons, including communication and marketing purposes. We process your Personal Data collected by other means for other business reasons, including managing our business and our funds’ investments.

5. Is it necessary to provide Personal Data?

You are not required to submit information to us through this website. However, we may collect “cookies”, which do not require your consent. For our service providers, vendors, investors and other contacts, it is necessary to provide some Personal Data in order for us to do business with you.

6. With whom do we share your Personal Data?

We will not share your Personal Data with third parties except in the context of those third parties acting as data processors. For example, we may use a customer relationship manager software platform to organize our business contacts, and your Personal Data may reside on that software. Where relevant, we will ensure that contractual safeguards are implemented with these third-party data processors to ensure the protection of your Personal Data.

GTIS Partners does not sell or transfer Personal Data to affiliates or third parties for value and does not intend to do so in the future. We will amend this Privacy Notice promptly upon any changes to this policy.

You may access a list containing the categories of third parties with whom we may share your personal data by contacting compliance@gtispartners.com (mailto:compliance@gtispartners.com)

7. Will we transfer your Personal Data abroad?

We may transfer information about you to our affiliates or service providers abroad in the course of the legitimate operation of our business. We have safeguards in place so that any transfer of data is subject to an adequate level of data protection as mandated by the privacy regulations applicable. You may request a copy of such safeguards by contacting us (see “Contact Information” bellow).

You may also access a list containing the countries to where we may internationally transfer your personal data by contacting compliance@gtispartners.com (mailto:compliance@gtispartners.com)

8. How long do we retain your Personal Data?

Your Personal Data will be retained for as long as you are one of our business contacts, or longer as required by applicable law. Your Personal Data may be deleted when it is no longer relevant or when you withdraw consent (see directly below), again within the parameters of applicable law. If we send you emails and/or market to you, you may unsubscribe at any time from communications from us, and we will cease sending you further communications.

9. What are my rights with respect to my Personal Data?

Your rights described in this Privacy Notice are applicable only if you reside in a jurisdiction where the provision of such rights is required by the data protection and privacy laws of the governing regulatory authority, as outlined further below. These rights may be limited and subject to further legal requirements.

California Consumer Privacy Act, 2020

  • The right to be informed about what Personal Data is being processed and the rationale for the processing;
  • The right to know whether and to whom your Personal Data is sold or disclosed and to opt out of the sale, if applicable;
  • The right to access (i.e. view or request copies of) your Personal Data that is being processed;
  • The right to request that we delete your Personal Data under certain circumstances; and
  • The right to not be discriminated against for exercising your rights under the California Consumer Privacy Act.

GDPR, 2018

  • The right to be informed about what Personal Data is being processed and the rationale for the processing;
  • The right to access (i.e. view or request copies of) your Personal Data that is being processed;
  • The right to request that we rectify Personal Data if it is inaccurate or out of date;
  • The right to request that we delete your Personal Data (the right to be “forgotten”) under certain circumstances;
  • The right to restrict processing your Personal Data if you contest its accuracy, the lawfulness of its processing or if we no longer need it;
  • The right to object to the processing of your Personal Data if processing is based on our legitimate interests or for direct marketing purposes;
  • The right to be informed about and object to the existence of automated decision making, including profiling, and about its significance and consequences on you; and
  • The right to request a transfer of your Personal Data to a third party in certain circumstances.

Cayman Islands Data Protection Law, 2017

  • The right to be informed if your Personal Data is being processed and of the identity of the data controller and the purposes for which your Personal Data is being processed;
  • The right to access your Personal Data, including a description of the data, the purposes for which it is being processed and the recipients to which the Personal Data was disclosed;
  • The right to have your Personal Data, if inaccurate, be rectified, blocked, erased or destroyed;
  • The right to have the data controller cease processing your Personal Data, unless certain conditions are met;
  • The right to require that the data controller not take any action with your Personal Data as a result of automatic decision making;
  • The right to cease direct marketing; and
  • The right to receive compensation for damage as a result of the processing of your Personal Data.

Brazilian General Data Protection Law, 2018

  • The right to obtain from us confirmation as to whether or not your Personal Data are being processed and, where this the case, obtain a copy of the Personal Data undergoing processing;
  • The right to request that we correct, supplement or update your Personal Data;
  • The right to request us to anonymize, block or delete your Personal Data if no longer necessary, if excessive, or if your Personal Data have been unlawfully processed;
  • The right to be informed about the public and private entities with which we have shared your Personal Data;
  • The right to oppose the processing carried out based on one of the situations of waiver of consent, where there is noncompliance with the applicable law;
  • The right to request for the review of decisions that affect your interests and that were made by us solely based on automated processing of your personal data;
  • The right to portability of the data to another service provider or product provider, subject to our commercial and industrial secrets;
  • The right to petition before the Brazilian National Data Protection Authority or before consumer-defense entities if you believe that we have breached privacy regulations applicable requirements;
  • The right to be informed about the possibility of denying consent and the consequences of such denial, where your consent is necessary for the processing of your Personal Data;
  • The right to request the deletion of personal data processed with your consent;
  • The right to withdraw consent at any time, if your personal data is being processed by us under this legal basis.

In order to exercise the above listed rights or any other right that may be provided by the data protection and privacy laws of your jurisdiction, you can contact GTIS Partners DPO (see “Contact Information” bellow).

10. What security do we have in place over your Personal Data?

GTIS Partners has implemented appropriate procedural and technical security measures to help protect your Personal Data against loss and to safeguard your Personal Data against access by unauthorized persons. We consider the protection of sensitive information to be a sound business practice and a top priority, and to that end we employ physical, electronic and procedural safeguards to protect your Personal Data. If you would like to request more information regarding the procedural and technical safeguards we have in place, please contact us at the email address below.

11. What are our procedures in the event of a breach to your Personal Data?

Depending on the applicable law, GTIS Partners may be required to notify you or the appropriate authority in the event of a breach. States that have enacted data protection laws may require different procedures in the event of a breach of your Personal Data, including with regard to notification to certain regulators or agencies and the data subject; in each case and in the event of such a breach to your Personal Data, we will follow the laws of the applicable jurisdiction.

12. Updates to this Privacy Notice

This Privacy Notice was updated in September 2020. We may amend this Privacy Notice from time to time to reflect changes in our practices with respect to the processing of Personal Data or changes in applicable law.

13. Contact Information

If you have any questions about how we process your Personal Data, please contact us at compliance@gtispartners.com (mailto:compliance@gtispartners.com).