Greenspring Associates, LLC (“Greenspring,” “we,” “us” or similar pronouns) is committed to protecting your privacy. This Website Privacy Notice (this “PrivacyNotice”) explains how Greenspring collects, uses, and shares your personal information through our websites or online services on which it is posted (referred to collectively in this Privacy Notice as our website(s)). This Privacy Notice applies to information we collect through our website, including about:
- Visitors to our website
- Individuals who contact us through our website in relation to our services, or as a potential employee or business partner
- Individuals who access gated content on our website
As used in this Privacy Notice, “personal information” means information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information.
1. How We Collect and Use Information
We collect different categories of information about you (including personal information) from different sources, including information you provide to us and information about your visits to our website, and use it for a range of purposes. Some examples are described below.
When you contact us through our website or through email, we collect your name, email address and your message. We use this information to respond to your message and as further provided in this Privacy Notice.
If you contact us in regard to an application for employment or when you submit an application online, we may collect your name, email, contact information and information about your employment history, education and other similar information. We use this information to process and respond to your application, and we may share this information with our affiliates or portfolio companies as applicable.
If you are an investor, potential investor or former investor, we collect your information orally, in writing or electronically, including as set forth in your subscription agreement, investor questionnaire or similar forms, including but not limited to your name, address and social security or tax identification number, telephone number, assets, income and investment experience, capital commitments, and other information included in your communications to us concerning your investment. We also collect nonpublic financial information such as information about your transactions and investments. You may contact us for a copy of the privacy notice applicable to other personal information collected about you in the context of our relationship with you.
If you are an employee of a portfolio company, we may collect information about you and your company to inform our investment decisions, provide our services, conduct due diligence, and comply with our legal obligations.
If you create an account to access gated content on our website, we will collect your name and email address and any information you provide through the dashboard or in the data room. This information is maintained in accordance with our legal and contractual obligations in our agreements with you.
We may also collect information about you from third party sources, such as credit bureaus and consumer reporting agencies, professional advisors and similar entities, which we may combine with the information we collect from you in order to help us provide our services or to comply with our legal and regulatory obligations, in particular regarding anti-money laundering, bribery and financial regulations.
We use your personal information primarily for our business purposes, including to fulfil our contractual obligations to you and / or to investors who you represent. We will also use your personal information to pursue our legitimate interests, including for marketing purposes and for risk assessment purposes as required by law (or if not required by law where they are in our legitimate interests) in connection with our compliance obligations for example, aimed at the prevention of money laundering or terrorist financing and tax law (under any tax reporting regime) and “Know Your Customer” requirements. If such checks are not conducted then we will not be able to carry out our contractual obligations arising under any agreement we have with you and / or the business that you represent. We also use your personal information to pursue our legitimate interests, namely: (i) for purposes of communicating with you concerning your current or previous investments; (ii) to tailor our advice and services to you and / or the business that you represent and process transactions; and (iii) to conduct our legitimate internal business operations including general administrative purposes and to maintain appropriate records and attend to correspondence.
As noted above, we may use your personal information to send you marketing materials that we think will be of interest to you and may request your consent for such communications (for example if required by applicable law). You have the right to unsubscribe from these communications at any time by contacting us using the details at the end of this Privacy Notice or clicking an unsubscribe link in these communications. Please understand that it may take us a few days to process any opt-out request and that even if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
2. How We Disclose Your Personal Information
We may disclose your personal information to the following categories of affiliated and nonaffiliated third parties:
- Investors in specific funds, consistent with industry practice (and the provisions of our fund agreements), including capital account information and various schedules to the respective partnership agreements;
- Affiliates (such as affiliated investment advisers and general partner entities under common control with us) and their employees and agents that have demonstrated a legitimate business need for the information;
- Third parties as needed to support and perform our services and / or protect the rights, property, or safety of Greenspring, its clients or others (e.g., our attorneys, broker-dealers, custodians, transfer agents, fund administrators, consumer reporting agencies and background check companies, lenders and accountants); and
- Service providers who help us deliver or improve our service or who perform services on our behalf, such as providing hosting and managed technology services, processing payments, sending postal mail, providing back-office services, or measuring site traffic.
Our policy is that these third parties may use personal information only for the purpose for which it was disclosed, or as permitted by applicable law or regulation.
We will also disclose personal information as required by applicable law or regulation, including but not limited to, responding to requests from government or self-regulatory organizations or in connection with U.S. or foreign anti-money laundering laws or similar requirements or as necessary or permissible under applicable laws, in connection with legal proceedings, or otherwise to assert and protect our legal interests, prevent harm or financial loss, or to investigate or fraud or illegal activity, or to enforce our agreements or as part of a corporate transaction (such as with an investor, acquirer, successor or other third party).
3. Cookies and Online Advertising
We automatically collect certain types of usage information when you visit our website, read our emails, or otherwise engage with us, and we may use third parties to collect this information through the use of tracking technologies, such as cookies, beacons, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, device type, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, your location (or we may approximate your location) and other such information. We also collect information about the way you use our website, such as the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the website from multiple devices, and other actions. We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for our website and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our users, we do not respond to Do Not Track signals set by your browser at this time and we do not require our third party partners who collect information about your online activities over time and across websites (such as analytics companies) to respond to such signals.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit our website; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise plan for and enhance our service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using our website, as some features and services on our website may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
We may permit third party online advertising partners to collect, information about your use of our website over time through tracking technologies such as cookies so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use. We and our third party partners use this information to make the advertisements you see online more relevant to you and your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your device or browser setting. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but you may still receive interest-based ads on other devices. You must perform the opt-out on each browser or device you use.
4. Data Protection and Security
We maintain physical, electronic and procedural safeguards designed to guard sensitive nonpublic personal information. However, due to the inherent nature of the internet as an open global communications vehicle, we cannot guarantee the confidentiality or security of any information, during transmission through the internet (including email) or while stored on our system or otherwise in our care. If you correspond with us by email, text message, or using web forms like a “contact us” feature on our website, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We accept no responsibility or liability for the security of your information while in transit over the internet.
If you create an account on our website, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.
We will retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
5. For Individuals Based in the European Economic Area (EEA) or Similar Jurisdictions
If you are based in the EEA or another jurisdiction with similar privacy laws, you have the following rights, in certain circumstances, in relation to the personal information we hold about you: (i) the right to obtain confirmation of whether we are processing your personal information and to access that personal information along with related information about the processing; (ii) the right to receive a copy of the personal information we hold in a format that supports re-use, or to request transfer to another person; (iii) the right to obtain rectification of any inaccurate or incomplete personal information; (iv) the right to require us to erase your personal information if continued processing is not justified; and (v) the right to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified.
You also may have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation.
If you wish to exercise any of these rights, please contact us using the details at the end of this Privacy Notice. You also have the right to lodge a complaint to your local data protection authority.
Whenever we transfer your personal information out of the EEA or another jurisdiction with similar privacy laws, we ensure a similar degree of protection is afforded to it by ensuring certain safeguards are implemented, such as that the transfer is made pursuant to a contract, or subject to a compliance mechanism, approved by the European Commission or applicable authority. Please contact us using the details at the end of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA or similar jurisdiction.
6. For Individuals Based in California
If you are a resident of California, you have additional rights with respect to your “personal information” as defined by the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq (“CCPA Personal Information”). For the purposes of this Privacy Notice, CCPA Personal Information does not include any information relating to employees or contractors of Greenspring, information that is publicly available from government records, or information that is governed by the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA).
In the last 12 months, we have not sold CCPA Personal Information about you to third parties. In the last 12 months, we have collected and disclosed the following categories of CCPA Personal Information for a business purpose:
|Category of CCPA Personal Information||Collected||Disclosed for Business Purpose|
|Identifiers, such as your name, social security number, and contact information||✔||✔|
|California Customer Records (Cal. Civ. Code § 1798.80(e))||✔||✔|
|Protected Classification Characteristics such as your citizenship or national origin||✔||✔|
|Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)||✔||✔|
|Inferences drawn from other personal information to create a profile about you||✔||✔|
To learn more about the purposes for which we collect and disclose this information as well as the categories of third parties to whom we disclose this information, please see Section 1-3 in this Privacy Notice above.
To learn more about the purposes for which we collect and disclose this information as well as the categories of third parties to whom we disclose this information, please see the information above in this Privacy Notice.
Residents of California may have the following additional rights, in certain circumstances, in relation to the CCPA Personal Information we hold about you: (i) the right to request a copy of the CCPA Personal Information we have collected about you in the last 12 months (other than personal information reflecting a written or verbal business-to-business communication (“B2B CCPA Information”) or personal information collected about job applicants or similar individuals and used only within the context of such a relationship (“Employment-Related CCPA Information”)); (ii) the right to request additional information about how we have collected and disclosed your CCPA Personal Information in the last 12 months (including the categories collected, the categories of sources, the purposes for collecting or sharing CCPA Personal Information, the categories of third parties with which we share CCPA Personal Information for a business purpose and, if applicable, the categories of CCPA Personal Information we have sold about you); (iii) the right to request deletion of CCPA Personal Information (other than B2B CCPA Information and Employment-Related CCPA Information) we have collected about you, subject to certain exceptions; and (iv) if applicable, the right to direct us not to sell CCPA Personal Information we have collected about you to third parties in the future. If you wish to exercise any of these rights, please contact us using the details at the end of this Privacy Notice and describe your request with sufficient detail for us to properly understand, evaluate and respond to it. We may request additional information from you in order to verify your identity or authority to make the request.
Additionally, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at [email protected] or writing to us at Greenspring Associates Attn: Compliance 100 Painters Mill Rd. Suite 700 Owings Mills, MD 21117.
7. Links to Third-Party Websites and Services
For your convenience, our website may provide links to third-party websites or services that are not owned or controlled by Greenspring. We are not responsible for those websites’ or services’ content or information practices, and their privacy policies (and not this Privacy Notice) will apply to information about you collected on those websites or services. We encourage you to review the privacy policies of any site or service before using it or providing any personal information.
8. Changes to this Privacy Notice
We reserve the right to change this Privacy Notice from time to time in our sole discretion. We will post changes on this page and indicate the “last revised” date at the end of this Privacy Notice. Please check back often for any updates.
9. Contact Us
For additional inquiries about this Privacy Notice, or to exercise your rights, please contact us at: [email protected]
Last Revised: April 20, 2020