GCM Grosvenor Privacy Notice
Effective September 7, 2018.
Grosvenor Capital Management, L.P., GCM Customized Fund Investment Group, L.P., GCM Investments UK LLP, and affiliated entities (collectively GCM Grosvenor, we and us) are providing this Privacy Notice to inform you about how we process the Personal Data that we collect through the Services. This Privacy Notice does not cover or apply to our investors and limited partners. We maintain a separate Investor Privacy Notice that describes how we process the Personal Data of our investors and limited partners.
Scope and Definitions
When we use the term “Services”, we mean to refer collectively to:
- The websites owned and controlled by us that link to this Privacy Notice (Sites);
- The provision of investment and related services in the conduct and operation of our business (Investment Services); and
- Marketing and business development activities, including events we host, social media properties we operate, and emails that we send (Marketing Activities).
When we use the term “Personal Data”, we mean information that one can reasonably use to identify an individual person or that reasonably relates to an identifiable person (Data Subject).
The Data Subjects we receive Personal Data from in providing the Services are:
- Directors, officers, employees, representatives and other individuals associated with the companies in which GCM Grosvenor has made an investment or is considering making an investment;
- Individual representatives of third party sellers, placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and other service providers, whether or not engaged by GCM Grosvenor;
- Directors, officers, employees and other representatives of GCM Grosvenor;
- Individuals applying for or inquiring about employment with us; and
- Visitors to our offices, events and conferences, Sites and users of any digital Services we provide.
The GCMGrosvenor.com Site
We operate the GCMGrosvenor.com (Site) through servers in the United States. BY USING THE SITE AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL DATA IN THE UNITED STATES.
Please be aware that the Site may contain links to other websites hosted by third parties. GCM Grosvenor does not control and is not responsible for the content or privacy practices and policies of such third party websites. We encourage you to be aware when you leave the Site and to read the privacy policies of each third-party website, especially if such website collects Personal Data from you.
What Personal Data We Collect
In connection with the Services, we collect:
- identification information—including name, ID card and passport numbers, nationality, place and date of birth, gender, picture, IP address
- contact information—including postal address and e-mail address, phone number
- family situation—including marital status, number of children
- tax status—including tax ID, tax residence
- professional and employment information—including resume details, work history, personnel files, pay and benefits information
- financial data—including bank account details, credit card number, money transfers, including communications regarding bank transfers, assets, investment profile, credit history, debts and expenses
- service data—including information on requests you make to provide our Services
- other background data—including information on criminal history and unlawful conduct, and
- health information—including if you attend one of our events, information like dietary restrictions or disabilities or if a business we are considering investing in makes the information available to us
How We Collect Personal Data
We collect this Personal Data in various ways, including:
- Directly from the Data Subject—for example, from visitors to our offices, visitors to our Sites, when you voluntarily submit information on our Sites, including to sign up for our mailing list, when you attend one of our events or conferences, when you apply for a job, send us an email, other written correspondence, or complete a form in connection with our Services;
- Indirectly from other sources—for example, when we are evaluating an investment opportunity and we receive diligence information from the target that may include Personal Data, when service providers provide us Personal Data in connection with their services, or when we undertake certain investment activities during which we may receive Personal Data from placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and others, whether or not engaged by GCM Grosvenor; and
How We Use Personal Data
We use Personal Data for a variety of business purposes.
When processing Personal Data in connection with our Investment Services, we generally rely on our legitimate business interests. These include:
- making, maintaining, managing and disposing of our investments;
- conducting due diligence and evaluating business opportunities;
- developing new investment opportunities;
- managing, operating and growing our business, administering the Services and managing investor accounts, including through the use of third party service providers;
- complying with legal or regulatory obligations, such as our obligations regarding tax withholdings;
- processing and considering applications for employment, including evaluating and confirming your suitability for a position and accuracy of any information submitted;
- monitoring and auditing compliance with internal policies and procedures, legal obligations and to meet requirements and orders of regulatory authorities; and
- conducting risk mitigation activities to maintain and protect the safety and security of our Services, systems, premises and events, and to prevent and detect security threats, fraud or other criminal or malicious activities.
When processing Personal Data through our Sites and in connection with our Marketing Activities, we also generally rely on our legitimate business interests. These include:
- communicating with Data Subjects and building relationships with Data Subjects;
- conducting direct marketing activities and providing newsletters, updates, invitations and other information that we believe may be of interest to you; and
- administering, improving and customizing our Sites and understanding how our Services are used.
We also may process Personal Data to perform a contract with you or to take steps at your request before entering into a contract, including to: (i) provide you with information regarding GCM Grosvenor Services, (ii) assist you and answer your requests, or (iii) evaluate whether we can offer you GCM Grosvenor Services and under what conditions.
We also may process Personal Data with your consent, but only in those cases where we make it clear to you in advance that we are relying on your consent for the processing.
How we share Personal Data
- Within GCM Grosvenor: We share your Personal Data within GCM Grosvenor for the purposes set forth above.
- Service Providers. We may disclose your Personal Data to third-party service providers to provide us with services such as website hosting, professional services, including information technology services and related infrastructure, customer service, e-mail delivery, auditing and other similar services.
- Affiliates. We may disclose Personal Data to our affiliates for the purposes described in this Privacy Notice, including for their marketing purposes, and to be consistent with our goal of providing the superior client service and engagement experience that our clients have come to expect from us around the world.
- To Perform Investment Services. We will also disclose Personal Data to the following categories of third parties: (i) anyone involved in the matter we are working on, including lawyers, barristers, counterparties, experts, mediators, opponents, attorneys and witnesses, (ii) law enforcement, tax and regulatory agencies and bodies, (iii) insurers, and (vi) service providers such as IT and telephone services, catering, document production and postal and delivery services.
- Fulfill Requests. We may disclose Personal Data to third parties in order to perform services you request or functions you initiate, including when you post information and materials publicly on message boards and forums.
- Corporate Transactions or Events. We may disclose your information to a third party in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital, including in connection with any bankruptcy or similar proceedings.
- Other Legal Reasons. In addition, we may use or disclose your Personal Data as we deem necessary or appropriate: (1) under applicable law, including laws outside your country of residence; (2) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (3) to comply with subpoenas and other legal processes; (4) to pursue available remedies or limit damages we may sustain; (5) to protect our operations or those of any of our affiliates; (6) to protect the rights, privacy, safety or property of GCM Grosvenor, our affiliates, you and others; and (7) to enforce our terms and conditions.
How we protect Personal Data
GCM Grosvenor seeks to maintain physical, electronic, and procedural safeguards in accordance with our information security program in order to protect your personal data from unauthorized access or use. However, no data transmission or storage system can be guaranteed to be secure at all times. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
How long we retain Personal Data
GCM Grosvenor retains personal data pursuant to our records retention program for as long as is necessary for the purposes set out in this Privacy Notice, unless a longer period is required or permitted under applicable law or is needed to resolve disputes or protect our legal rights.
Keeping Personal Data current
In general, we seek to ensure that we keep your Personal Data accurate and up to date. However, you are responsible for, and we kindly request that you inform us of, any changes to your Personal Data—such as a change in your contact details. To update or edit your Personal Data that we have on file, including your communication preferences, please contact us using the contact details set out under the “Contact and Complaints” heading below or by sending an e-mail to firstname.lastname@example.org.
For individuals in the European Economic Area, please click here for additional detailed disclosures.
Contact and Complaints
GCM Grosvenor takes very seriously any complaints we receive about our use of your Personal Data. Please send any questions, comments, requests, or complaints regarding the Site, this Privacy Notice, the user agreement and our use of your Personal Data to email@example.com.
We will treat any Personal Data we receive from you when making a complaint in accordance with this Privacy Notice and only to process the complaint and check on the level of service we provide. Similarly, where you submit inquiries to us, we will only use the information supplied to us to deal with the inquiry and any subsequent issues and to check on the level of service we provide.
ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA)
The below information applies to any Data Subject resident in the EEA. For purposes of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 (the GDPR), we act as a “data controller” and our headquarters is located in the United States at 900 North Michigan Avenue, Suite 1100, Chicago, IL 60611, and we are also located in the United Kingdom at 33 Jermyn Street, Level Seven, London SW1Y 6DN. As a data controller, we are responsible for deciding how we hold and use Personal Data about you.
GDPR Data Protection Principles
In respect of the collection, holding, storage, use, and processing of your Personal Data:
- We will process the data lawfully, fairly and in a transparent way.
- We will obtain the data only for valid purposes that we have clearly explained to you and not use data in any way that is incompatible with those purposes.
- The data we collect will be relevant to the purposes we have informed you about and limited only to those purposes.
- We will take reasonable steps to ensure that the data is accurate and kept up to date.
- Subject to applicable legal or other requirements, we will keep the data only as long as necessary.
- We will use appropriate technical and/or organizational measures to ensure appropriate security of the data.
Transfer of Personal Data Outside of the EEA
The transfer of Personal Data from the UK/EEA to the GCM Grosvenor entities outside the EEA is governed by data transfer agreements, which are in the form of the standard contractual clauses approved by the European Commission—a copy of which can be obtained from us via the contact details below.
Where your Personal Data is processed by third parties outside of the EEA, we will ensure that appropriate safeguards are in place to adequately protect your Personal Data, as required by applicable law, including the execution of standard contractual clauses if the recipients are not located in a country with adequate data protection laws—as determined by the European Commission—or certified under the EU-US Privacy Shield framework.
GDPR Data Subject Rights
Under the GDPR, in certain circumstances, an EEA-resident Data Subject has certain individual rights with respect to the Personal Data that we hold about them. In particular, you may have the right to:
- Request access to any data held about you 
- Ask to have inaccurate data amended
- Request data held about you to be deleted, provided the data is not required by GCM Grosvenor to perform a contract, defend a legal claim or to comply with applicable laws or regulations
- Prevent or restrict processing of data which is no longer required
- Request transfer of appropriate data to a third party where this is technically feasible
Additionally, in the circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific purpose 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 we have another legitimate basis for doing so in law. However, if you decline to provide or consent to our use of the data and we are relying on consent as the legal basis for its processing, there are circumstances in which we will not be able to provide you with Services or take action on your behalf.
To exercise any of these rights, please contact us using the contact details set out under the “Contact Us” heading below. As a resident of the EEA, you are also entitled to direct any complaints in relation to our processing of your Personal Data to your national or local data protection supervisory authority.
Automated Decision Making
We respect your legal rights not to be subject to decisions that are based solely on automated processing of your Personal Data, including profiling, especially where such processing has legal or other significant effects on you. In establishing and carrying out a business relationship, we generally do not use any automated decision-making pursuant to the GDPR. We may process some of your Personal Data automatically, with the goal of assessing certain personal aspects (profiling), such as to comply with legal or regulatory obligations to combat money laundering, terrorism financing, and offenses that pose a danger to assets.
|Grosvenor Capital Management, L.P.
900 North Michigan Avenue, Suite 1100
Chicago, IL 60611
+1 (312) 506-6500
|GCM Investments UK LLP
33 Jermyn Street, Level Seven
London SW1Y 6DN
+44 (0) 20 3727 4450
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