GEF CAPITAL PARTNERS PRIVACY NOTICE

Last Updated: May 29, 2024

This Privacy Notice describes how the affiliate entities commonly known as “GEF Capital Partners” (including South Asia Advisors LLP) (“we”, “us”, “our”) collect, use and disclose information about you when you use our website (https://gefcapital.com/) or otherwise interact with us (collectively, the “Services”). If you are an investor with us, please see the Notice Regarding Privacy of Financial Information in your subscription documents for additional information on how we handle your non-public personal information.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services.

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF INFORMATION

Information You Provide to Us

Some features of the Services may require you to directly provide certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes:

• Basic contact details, such as name, address, phone number, and email. We use this information to create and maintain your account and provide the Services, as may be required to perform our contract with you, and because it is in our legitimate interest to communicate with you (including to tell you about products or services that may be of interest to you).
• Applicant details, such as such as information included in your resume or CV, references, job history, and other information an applicant chooses to provide. We use applicant details to process your application for employment and because it is in our legitimate interest to evaluate your candidacy.
  Any other information you choose to include in communications with us, for example, when sending a message through the Services, because it is in our legitimate interest to be responsive to you.

Information Collected Automatically

We may also use cookies or other tracking technologies to automatically collect certain information about your interactions with the Services, such as IP addresses, device type, unique device identifier, and other information regarding how you navigate the Services. We collect and use this information because it is in our legitimate interests to tailor your experience with the Services and better understand user interactions with the Services.

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you choose, you may block or delete certain of our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly. Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

3. DISCLOSURE OF YOUR INFORMATION

We may disclose your information for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:

• Our affiliates or others within our corporate group, as a matter of our legitimate interests to efficiently provide the Services (“Affiliates”).
• Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, customer relationship management, marketing communications, and web analytics (“Service Providers”).
• Financial institutions we have partnered with when you have requested that we share certain information, pursuant to your consent or our contract with you (“Financial Institutions”).
• Professional advisors, such as auditors, law firms, or accounting firms, as a matter of our legitimate interests to assess, protect, enforce and defend our rights and to comply with our legal and regulatory obligations.
• 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.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or in our legitimate interests to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

4. DATA SECURITY 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. We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

5. CALIFORNIA RESIDENTS

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, the term “personal information” has the meaning provided in the California Consumer Privacy Act (“CCPA”).

Processing of Personal Information 

In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information about residents:

The specific business or commercial purposes for which we collect and disclose your personal information and the categories of sources from which we collect your personal information are described in the sections above, Collection and Use of Information.

We do not “sell” or “share” (as those terms are defined under 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.

Your California Privacy Rights

As a California resident, you may have the rights listed below in relation to personal information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

• Right to Know. You have a right to request the following information about our collection, use and disclosure of your personal information:
  • categories of personal information we have collected, disclosed for a business purpose;
  • categories of sources from which we collected personal information; o the business or commercial purposes for collecting personal information;
  • categories of third parties to whom the personal information was disclosed for a business purpose; and
  • specific pieces of personal information we have collected.
• Right to Delete. You have a right to request that we delete personal information we maintain about you.
• Right to Correct. You have a right to request that we correct inaccurate personal information we maintain about you.

You may exercise any of these rights by contacting us using the information provided below. We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your government issued ID and date of birth, before providing a substantive response to the request. You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

6. INTERNATIONAL RESIDENTS

Data Transfers

The information that we collect from you may be accessed from, transferred to, and stored and used in countries outside the country in which you are located, by us and by our third party service providers or partners. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Notice. Where required by law, we will only transfer your information across international borders where appropriate safeguards are in place, such as standard contractual clauses.

Privacy Rights

Depending on your location, you may have certain rights in relation to your personal data. Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. To exercise any of these rights, you can contact us at the email address provided below:

• Access: You have the right to access the personal data we hold about you, and to obtain information about how we use it, and who we share it with.
• Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Correction: You have the right to correct any of your personal data we hold that is inaccurate.
• Erasure: In certain circumstances, you have the right to delete the personal data we hold about you.
• Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.
• Objection: You have the right to object to our processing of your personal data in certain circumstances.
• Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe / opt-out function displayed in our communications to you. Please note that if you optout of receiving marketing-related emails from us, we may still send you administrative messages that are required to provide you with the Services.
• Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by contacting us at the email address provided below.
• Complaints: You have the right to complain to your local data protection authority about how we process your personal data. Of course, we hope you will contact us first so we can resolve any issues.

7. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at contact@gefcapital.com