Privacy Policy

Notice of Privacy Policy
Great Hill Partners, L.P.
Last Updated: April 8, 2025

Great Hill Partners, LP and its affiliates (“GHP”, “we”, “us”, or “our”) are committed to protecting the privacy of personally identifiable information (“PII”) of identifiable individuals who visit www.greathillpartners.com and our investment portal (together, the “Site”), inquire about or use services associated with our business available through our Site or in the course of investing in one of our funds (collectively, the “Services”), or express interest in our business. The privacy of your PII is important to us at GHP. This Privacy Policy discloses the privacy practices for GHP and for its Site, and localized versions of that site, including the type of PII collected and tracked, how the information is used, and with whom the information is shared. This Privacy Policy also describes how we collect, use and disclose PII about prospective, current or former investors.

In order to provide you with Services you may request, it is necessary for us to possess some PII of yours. Similarly, without some of that information, we cannot inform you about the Services we have available or that you may request (though if you are currently receiving marketing communications from us, you may opt-out of receiving further communications at any time) or appropriately manage your investment. This Privacy Policy explains our PII policies and practices. It includes, but is not limited to, explanations of the types of PII we may collect about you, the purposes for collecting such information, the circumstances under which we may disclose such information to third parties, the measures we take to secure the confidentiality of such information, your rights regarding your PII, and the way to contact us to exercise those rights. Your use of the Services shall constitute your acceptance of this Privacy Policy.

Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendments. If we make material changes to how we process your PII, we will take reasonable steps to notify you in accordance with applicable law.

TYPES OF INFORMATION WE COLLECT

This section explains the PII that may be collected when using our Services, when submitted in subscription agreements or other forms, and in communications with us. It also explains the PII we may receive from other sources, including, without limitation, banks that offer opportunities to invest in our funds. PII that we collect about you includes:

Contact details, such as your full name, e-mail address, postal address and telephone number.
Educational, nationality and professional background information.
Other information relating to an investment, such as the investor’s tax identification number, information about the investors’ transactions with us, participation in other opportunities, ownership of accounts, account transactions, other account information and anti-money laundering and Know Your Client (KYC) information (such as home address, driver’s license and passport numbers and utility bills).
Information captured through our Services, including registration information like usernames and passwords, and information captured via Cookies (as defined below).
Payment and transaction information. For example, we may receive payment information from the company you use to pay us in order to correct our records.
Credit or identity information, which we use to help prevent and detect fraud.
Comments, feedback, posts and other content submitted to staff.
Interests and communication preferences including marketing permissions where appropriate.

RESTRICTED USE REGARDING MINORS

This Site is not intended or designed to be used by children under the age of 13. We do not collect PII from any person we know to be under the age of 13 and instruct children under 13 not to send us any information.

PURPOSES FOR COLLECTING YOUR PII

You may provide your PII to GHP in order to fulfill a Service. You are then entering a business relationship with GHP and are agreeing to the use of that data by GHP and its applicable worldwide affiliated companies, as stated in this Privacy Policy. We collect your PII for a variety of purposes throughout your interaction with GHP, including:

Contacting you or your designated representative by phone, email, fax, or mail.
Providing you or your representative with marketing communications.
Creating and managing your account with us.
Sharing information about our Services including investment research.
Facilitating financial transactions related to your account.
Fulfilling our legal and regulatory obligations.
The performance of obligations under any applicable agreements.
The administrative processes (and related communication) carried out by GHP in preparing its services.
Ongoing communication with you and/or your designated contacts.
The ongoing administrative, reporting and other processes and communication required to operate the business in accordance with the agreements and other applicable documentation between the parties.
To collect information for our recruiting process.
Any legal or regulatory requirement.
Any other purpose that has been notified, or has been agreed, in writing.

LAWFUL BASIS

There is a need to process PII for the purposes set out in this Privacy Policy as a matter of contractual necessity under or in connection with the applicable agreement (particularly purposes 1, 3, 4, 5, and 7 above), and in the legitimate interests of GHP to operate their respective businesses (particularly purposes 8, 9, 10, 11 and 12 – and in some jurisdictions purpose 2 – above). From time to time, GHP may need to process the PII on other legal bases, including: to comply with a legal obligation (particularly purpose 6 above); if it is necessary to protect the vital interests of an investor or other data subjects; with your consent if this is required under law (in some jurisdictions, purposes 2 above); or if it is necessary for a task carried out in the public interest.
A failure to provide the PII requested to fulfill the purposes described in this Privacy Policy may result in GHP being unable to provide the services in connection with the terms of the subscription agreement.

DATA STORAGE AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information. Your PII will be retained only for as long as the information is needed to fulfill the purposes for which it was collected and processed. We will also retain and use your PII for as long as necessary to comply with our legal obligations and business requirements and/or to resolve disputes and enforce our agreements, terms of service and policies. If you stop using our Services, we will store your information in an aggregated and anonymized format.

PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION

We maintain physical, electronic, and procedural security measures designed to safeguard your PII. These measures include computer safeguards and secured files and buildings. Access to such information is restricted to those employees who are trained in the proper handling of client information and have a legitimate business need to access that information. We follow generally accepted standards to protect the PII you submit to us, whether that information is in transit or at rest. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

OUR SITE AND USE OF COOKIES

We use various technologies to collect other types of information stored on your device, including PII, automatically such as cookies, web beacons, pixels, IP addresses and tracking technologies (collectively, “Cookies”) when you use our Sites or Services. "Cookies" are small data files that are stored on or access data from your device that store certain information, including certain PII, accessible to our Sites, such as your password and any information content preferences you may voluntarily set at our Sites. These technologies help us ensure the security of the Site and Services. In particular, we use:

Strictly necessary Cookies. These Cookies are essential to the functioning of our Services, and enable us to provide a service requested by you or to comply with the law (e.g. security requirements under data protection law). This category of Cookies cannot be deactivated.

We do not need to obtain your consent in order to use these Cookies and these Cookies cannot be turned off as we cannot provide the Services without them. If you set your browser to refuse these Cookies, some aspects of the services on the Services will not be provided in an optimal manner, or will not be provided at all.

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You can refuse the use of Cookies by selecting the appropriate browser setting. If you refuse Cookies, please note that your experience using the Sites may not be optimal, and you may not be able to use certain features on our Sites.

For information on how to remove or manage Cookie functions and adjust your privacy and security preferences, access the “help” menu on your internet browser, or visit http://www.aboutcookies.org/how-to-control-cookies.

Your browser settings may allow you to transmit a “Do Not Track” signal, “opt-out preference” signal, or other mechanism for exercising your choice regarding the collection of your information when you visit various websites. Like many websites, our website is not designed to respond to such signals, and we do not use or disclose your information in any way that would legally require us to recognize opt-out preference signals.

SHARING YOUR PII

Your PII may be combined with information we receive from other sources, or it may be provided to other companies we work with. This section details that sharing of your PII. If you are an individual investor in the United States, and PII we collect about you is subject to the Gramm-Leach-Bliley Act, please note that we do not disclose any of your PII in a manner that would require us to provide you with the right to opt-out of such sharing.

Sharing PII with Third Parties

We may share your PII for the purposes of operating our business, delivering and improving the Services we provide to you, as well as for other purposes described in this Privacy Policy, such as sending marketing and other communications related to our business.

We may share your PII with third parties for a variety of additional purposes including:

Within GHP and our affiliates and subsidiaries for data processing or storage purposes.
With business partners, suppliers and other companies that perform various services for us to enable us to provide Services and help facilitate transactions (including processing orders, event registrations, data storage, marketing communications, sanctions, Know Your Client (KYC) and anti-money laundering requirements, and customer support).
With third parties to whom you request or direct us to disclose information.
With third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction, as a matter of our legitimate interests to run a successful and efficient business.
In response to a request from law enforcement, tax authorities, auditors, tax advisors, securities regulatory authorities, government authorities, or other third parties as necessary to comply with legal process or to meet national security requirements.
Where permitted by law, to other vendors, service providers, prospective or current investors in applicable funds, employees, agents, contractors, consultants, professional advisers, lenders, data processors and persons employed and/or retained by them in order to fulfill the purposes described in this Privacy Policy.

TRANSFERS OF PII

Your PII may be transferred, processed and/or stored in a country other than the one in which your PII is collected. When transferring your PII to the US or other countries, we have implemented procedures to ensure that appropriate safeguards are in place to protect the PII regardless of where it is being transferred to.

GHP may transfer PII outside of the EU or UK in order to fulfill the purposes described in this Privacy Policy and in accordance with applicable law, rule or regulation, including where such transfer is a matter of contractual necessity to enter into, perform and administer agreements, and to implement requested pre-contractual measures. For any transfers of PII outside the EU or the UK, the data transfer will be under the European Commission’s standard contractual clauses for the transfer of personal data to third countries specifically, module one (controller to controller transfer) or module two (controller to processor transfer), as relevant), or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their PII (e.g., transfers between the EU and UK). For information on the safeguards applied to such transfers, or should you wish to examine a copy, please contact legal@greathillpartners.com.

INFORMATION FOR EUROPEAN RESIDENTS

Rights

The General Data Protection Regulation (“GDPR”) in the European Union and UK grants EU and UK residents certain rights over their PII. The GDPR allows individuals to access their PII and find out details of how that data is processed, to rectify inaccurate PII, to have their data erased (when certain conditions are met), to restrict processing of their data, and more. It requires affected companies to create processes to comply with and facilitate consumer data requests, to update their privacy policies, and to ensure that PII is secured.

Specifically, the GDPR and other national privacy laws provide data subjects with certain rights regarding their PII. If you are an individual who resides in the EU and whose PII is collected and processed by GHP, you have the right to:

Request access to your data.
Rectify your data.
Take your data (in a readable, “portable” format) to another service provider.
Erase your PII.
Restrict or object to the processing of your PII.
Lodge a complaint with a and EU or UK data regulator or supervisory authority.
Withdraw previously given consent to collect and process PII (which will not impact PII processed before the withdrawal).

Controller

If you are an investor, the controller of your PII and the controller’s contact details are specified in your investment document.

Otherwise, the controller of your PII is Great Hill Partners UK LLP, with registered address at 60 Charlotte Street, 7th Floor, London, W1T 2NU. You can contact the controller at legal@greathillpartners.com.

INFORMATION FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) requires us to make certain additional disclosures and provides California residents with the ability to request additional information about their PII. If you are a California resident and it is determined that the CCPA applies to you, this section applies to you.
Please note that certain PII we collect is exempt from the requirements of the CCPA and the rights that you may have under the CCPA, such as nonpublic 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).

Processing of Personal Information

In the preceding 12 months we have collected and (where indicated) disclosed for a business purpose the following categories of information (sensitive information denoted by a ): identifiers; personal information listed in the California Customer Records statute (like your full name or contact information); professional, employment or education information; commercial information; internet or other electronic network activity information; inferences drawn from any information you provide to us (such as interests and communications preferences including marketing permissions where appropriate); login credentials for the investor portal; driver’s license and passport numbers; Social Security number or other tax identifier; and nationality*. The specific purposes for which we collect your PII and the categories of sources from which we collect your PII are described in the “Types of Information” section above. For further information on the purposes for which we disclosed personal information over the preceding 12 months, see the “Purposes for Collecting Your PII” section above. We only use and disclose sensitive personal information for the purposes specified in the CCPA.

We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we sell or share personal information of residents under 16 years of age.

Rights

If you are an individual who resides in California and whose PII is collected and processed by GHP, you may have the right to:

Request to know about our collection, use, and disclosure of your PII.
Request that we delete the PII we have collected about you.
Request that we correct the PII we have collected about you.

We will not discriminate against any consumer who exercises the rights set forth in this Privacy Policy.

We may need to collect information from you to verify your identity, such as your contact information, before providing a substantive response to the request.

QUESTIONS OR CONCERNS AND EXERCISING YOUR DATA SUBJECT RIGHTS

If you have any questions or concerns regarding the information in this Privacy Policy, or would like to exercise any of your rights set forth in this Privacy Policy, please contact this number +1-617-790-9400 or legal@greathillpartners.com. Please include a description of what right you want to exercise and the information to which your request relates. Please note that you may only make a disclosure request twice within a 12-month period.

Verifying Your Identity

If you choose to contact us with a request, you will need to provide us with identifying information that matches the PII we currently have about you.

Authorized Agent

You have the right to appoint an authorized agent to exercise your rights on your behalf. If you would like to do so, please contact legal@greathillpartners.com.

Accessibility Information

For consumers with disabilities who need to access this policy in an alternative format, please contact: legal@greathillpartners.com.