Privacy Policy
Last updated: September 5, 2022
GD1 Privacy Policy
GD1 Services Limited,(including any subsidiaries or affiliates of GD1 Services Limited, including but not limited to;
(i) GD1 Fund II (GP) Limited as general partner of GD1 Fund II LP;
(ii) TGF GP Limited as the general partner of Technology Growth Fund LP,
(iii) GD1 Fund 3 GP Limited as the general partner of GD1 Fund 3 LP, and
(iv) GD1 Management (Fund 3) Limited the fund manager for GD1 Fund 3 LP,
together "GD1", "we", "us","our"), invests in early stage concepts and ventures.
For the purposes of DataProtection Legislation each GD1 entity is a controller of personal data.
To enable us to make such investments and to offer Services as detailed on our website, it is necessary for us to collect and process personal data. We are committed to protecting your personal data and using it in compliance with Data Protection Legislation.
This privacy policy ("Privacy Policy") describes our policies and procedures on what information we collect from you or you provide to us, how we use it and with whom we share that information. The PrivacyPolicy also sets out your rights and who you can contact for more information.
Interpretations and Definitions
· your information is sometimes called "personal data";
· we may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as "processing" such personal data;
· the term "Data Protection Legislation"means any legislation relating to privacy or data protection which is applicable to GD1; and
· the following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
Account means a unique account created for you to access our Service or parts of our Service.
Company (referred to as either "the Company", "We", "Us" or"Our" in this Agreement) refers to Global from Day One , Suite 6.3Level 6, Alberts, Auckland 1010.
Cookies are small files that are placed on your computer, mobile device or any other device by a website ,containing the details of your browsing history on that website among its many uses.
Country refers to: NewZealand
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to theWebsite.
Service refers to ourWebsite.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate theService, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from theService infrastructure itself (for example, the duration of a page visit).
Website refers to GlobalFrom Day One, accessible from gd1.vc
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
1 What information we collect about you
GD1 may collect, record, disclose or use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data ProtectionLegislation and as set out in this Privacy Policy.
The personal data we handle, collect and process may include:
· information obtained from identification documentation (including your name, contact details, nationality and national identify numbers (where applicable));
· bank account details;
· your professional title and occupation;
· your age and marital status;
· usage data (including but not limited to; IP address, browser type, browser version, the pages of our website that you visit, the time and day of your visit, the time spent on those pages, unique device identifiers and other diagnostic data, in addition, if you access our website through a mobile device we may collect additional information relating to that device, we may also collect information that your browser sends to us whenever you visit our website or visit the site using a mobile device);
· financial information, tax status, account details and evidence of ownership of financial assets;
· personal identifiers such as your social security number, national insurance number, tax file / identification number, IP address or other internal electronic identifiers;
· information which we or our service providers need to conduct ‘know your client’ checks such as details relating to your passport or other identification documentation and credit history; and
· other information you provide in the course of your dealings with us or which they each require to provide you with products and services.
In certain circumstances, we also collect and process what are known as 'sensitive' or 'special categories' of personal data. Money laundering, sanctions, financial crime and fraud prevention checks sometimes result in GD1obtaining information about actual or alleged criminal convictions and offences.
If you fail to provide personal data we may be unable to provide certain products and services or proceed with your business relationship with GD1.
2 How we collect your information
The information we collect comes from:
· application forms, agreements, deeds or other materials you or your authorised representative submits to GD1 during the course of your relationship with GD1;
· information gained from AML/KYC checks that GD1 are required to conduct;
· your or your authorised representative's interactions with GD1, transactions and use of our products and services (including the use of our website);
· your or your authorised representative's business dealings with GD1, including via email, telephone or as stated in contracts with you;
· depending on the products or services you or your authorised representative requires, third parties (including for credit and money laundering checks, among other things); and
· recording and monitoring tools that they use for compliance or security purposes (e.g.recording of telephone calls, monitoring emails, etc.).
3 Tracking Technologies andCookies
In addition to collecting information using the methods identified above, we useCookies and similar tracking technologies to track the activity on our website and store certain information.
The technologies used may include beacons, tabs, and scripts to collect and track information and analyse the services we offer on our website. A description of some of these technologies is below:
· Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our website. Unless you have adjusted your browser setting so that it will refuse Cookies, our Service may use Cookies.
· FlashCookies. Certain features of our website may use local stored objects (or FlashCookies) to collect and store information about your preferences or your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
· WebBeacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit GD1, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. PersistentCookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser.
We use both Session and Persistent Cookies for the purposes set out below:
Necessary/ Essential Cookies
Type:Session Cookies
Administered by: Us
Purpose:These Cookies are essential to provide you with services available through our website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without theseCookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.
NoticeAcceptance Cookies
Type:Persistent Cookies
Administered by: Us
Purpose:These Cookies identify if users have accepted the use of cookies on the website.
FunctionalityCookies
Type:Persistent Cookies
Administered by: Us
Purpose:These Cookies allow us to remember choices you make when you use our website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use our website.
4 Accessing and correcting your information
Subject to certain grounds for refusal in Data Protection Legislation, you have the rights to:
· request confirmation from us as to whether we hold data relating to you;
· access your readily retrievable personal information that we hold; and
· request a correction to your personal information.
Before you exercise these rights, we will need evidence to confirm that you are the individual to whom the personal information relates.
In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the personal information, we will make the correction. If we do not make the correction, we will take reasonable steps to note on the personal information that you requested the correction.
Additionally if you are an individual located in the EU, you have the following additional rights: (i) to ask us to delete your information, if you consider that we do not have the right to hold it; (ii) to restrict processing of your information; (iii) to data portability (moving some of your information elsewhere) in certain circumstances; (iv) object to your information being processed in certain circumstances; (v) to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your information (GD1 does not carry out any automated decision making).
5 How we use your information
Our primary purposes in collecting your personal information is to administer the business of GD1, facilitate or administer the holding of shares in a GD1 fund, to provide and maintain the Service offered through our website, including monitoring the usage of that Service, and any related administration on anon-going basis.
Additionally, we use your information for the following specific purposes:
· to process transactions and to improve the quality of the service that we provide to you;
· to disclose information to other third parties such as service providers of GD1, auditors, regulatory authorities and technology providers (as set out in more detail below);
· to communicate with you as necessary in connection with the proper running of GD1;
· to update and maintain records, including GD1's register of partners, and carryout fee calculations;
· to monitor and record calls and electronic communications;
· in connection with GD1’s internal management and reporting;
· to report regulatory and tax related information to regulatory and tax authorities in order to comply with a legal obligation;
· permit, administer and record an investment in GD1;
· verifying the identity of the prospective investor to comply with statutory and regulatory requirements in relation to anti-money laundering procedures;
· to comply with our legal obligations;
· in order to carry out anti-money laundering checks and related actions which are necessary to comply with legal obligations, in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who maybe subject to economic or trade sanctions, on an on-going basis;
· for prudential and risk management purposes;
· to provide you with any products and services that you request from us;
· to manage your registration as a user of the Services offered on our website;
· for the performance of a contract – the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service;
· to contact you by email, telephone call, SMS, or other forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;
· to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information;
· we may use your information to and
· other reasons compatible with the primary purpose (set out above).
6 Grounds for using your personal information
We process your personal data because such use is necessary:
· for the purposes of the legitimate interests that we pursue, which are to run and administer GD1, to discharge our legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services;
· for the performance of a contract with you; and/or
· in order to comply with a legal obligation to which we are subject.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.
7 Providing your information to third parties
The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Policy:
· third parties such as service providers of GD1, auditors, regulatory authorities and technology providers, agents, contractors, service providers or related companies (including payment processors) if this is necessary to administer your investment in GD1, respond to your enquiries, provide access to ourService, or for any other related purposes;
· any regulatory, supervisory or governmental authorities to the extent we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud;
· with affiliates, in which case we will require those affiliates to honour this privacy policy. Affiliates may include any parent or holding company, subsidiaries, joint venture partners or other entities that we control or that are under common control with us; and
· tax authorities.
GD1 does not undertake marketing activities for third parties.
8 Transferring data outside of the EEA (EU investors only)
Personal data may be transferred to, and stored at, a destination outside the EuropeanEconomic Area ("EEA") or to countries not regarded by the European Commission as providing an adequate level of data protection. When we, or our permitted third parties, transfer personal information in this manner will ensure that the transfer is subject to appropriate safeguards in accordance with Data Protection Legislation.
We aim to ensure that the information we hold about you is accurate at all times.To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
9 How long we keep your information
We will only keep the information we collect about you for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
This will involve us regularly reviewing our files to check that information is accurate, up to date and still required.
The Company will also retainUsage Data for internal analysis purposes. Usage Data is generally retained fora shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
10 Transfer of Your Personal Data
Your information, includingPersonal Data, is processed at GD1’s operating premises and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this PrivacyPolicy followed by your submission of such information represents your agreement to that transfer.
GD1 will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless GD1 believes there are adequate controls in place including the security of your data and other personal information.
11 Disclosure of your PersonalData
Under certain circumstances, GD1 may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities(e.g. a court or a government agency).
GD1may disclose your Personal Data in the good faith belief that such action is necessary to:
· Comply with a legal obligation;
· Protect and defend the rights or property of the Company;
· Prevent or investigate possible wrongdoing in connection with the Service;
· Protect the personal safety of Users of the Service or the public;
· Protect against legal liability.
12 How we protect your information
We ensure that there are reasonable and appropriate technical, physical, electronic, and administrative safeguards in place to protect against such risks as loss, unauthorised access, destruction, modifications, disclosure orother misuse of personal information.
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
13 Links to Other Websites
OurService may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site.We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
14 Changes to Privacy Policy
ThisPrivacy Policy may be amended from time to time without notice, in which case the date of this Privacy Policy will be revised.
If our Privacy Policy changes in any way, we will place an updated version on this page. The change will apply from the date that we upload the revised Privacy Policy. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
15 Other
ThisPrivacy Policy is for your information and should not be used as the basis for any decision to purchase or redeem investments in GD1. The views and information expressed in this policy do not constitute and may not be relied upon as constituting any form of investment advice or inducement to invest, and prospective investors must obtain appropriate independent professional advice before making investment decisions.
16 Complaints
Questions, comments, complaints and requests regarding this Privacy Policy are welcomed and should be emailed to Catherine Young at cat@gd1.vc.
In certain circumstances you may also have the right to make a complaint to the supervisory authority which regulates and supervises the use of personal data in your jurisdiction.
