Privacy Policy

Georgian Partners is committed to protecting your privacy when you interact with this website.

Georgian Partners Growth LP (the “Company”, “Georgian”, “we”, “our” or “us”) values your privacy. This privacy policy (the “Policy”) applies to the website located at https://georgian.io/, (“the Site”), to all user portals available via the Site or available through other sites hosted or managed by Georgian, and to services offered by Georgian (the “Services”). In this Policy, we describe how we collect, use, disclose information that we obtain about visitors to our Site or that we may otherwise collect at events, such as conferences, or meetings in which we participate and those that we host. 

When we talk about “Personal Information” in this Policy, we are talking both about device information and information you knowingly provide to us. Personal Information is defined as information, in any format, about an identifiable individual and does not include aggregated or anonymized information. You understand that your Personal Information will be handled as described in this Policy. Your use of our Site, and any dispute over privacy resulting from your use of our Site, is subject to this Policy.

The information we collect through this Site is controlled by Georgian Partners Growth LP, which is headquartered in Canada at 2 St Clair Ave West, Suite 1400, Toronto, Ontario M4V 1L5 Canada.

THE INFORMATION WE COLLECT ABOUT YOU

We collect information about you directly from you and from third parties, as well as automatically through your use of our Site. We collect information from Site visitors when they contact us or access certain content, such as blogs, podcasts, or other content, from our Site. If you contact us or sign up for newsletter subscriptions, we collect your name, your company name and job title, your business contact information (such as your business phone number and email address), your country, and your reason for contacting us.  We also collect information from individuals at events, such as conferences, or meetings in which we participate and those that we host. This information includes names, job titles, business contact information, and company information.

If you seek to access investment information through the other portals hosted or managed by Georgian, we may ask you to create an account and profile. The account and profile will include information that can be used to identify you, including log in credentials. Within the Investor Portal you may submit or provide further Personal Information, such as name, address, government-issued identification information, and information relating to your investments, assets and income. In addition to this Policy, our collection and processing of investors’ Personal Information is subject to our Investor Privacy Notice, which we make available to you within the Investor Portfolio, your subscription documents, or otherwise at your request. If you are an investor and have questions about the Investor Portal, please contact privacy@georgian.io. 

If you apply for an open position advertised on the Site, we will collect the personal information you provide as part of your application: your full name, resume and qualifications, phone number and email address, in addition to other information you may choose to provide us such as your current employer and diversity information. 

We collect the following information about your use of our Site through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Site; the actions you take on our Site; and the referring URL, or the webpage that led you to our Site; which one you go to after; your browser type and selected language. We combine this information with other information that we have collected about you, including, where applicable, your name and other personal information. Please see the section “Cookies and Behavioral Advertising” below for more information.

HOW WE USE YOUR PERSONAL INFORMATION

We use your information, including your personal information, for the following purposes:

  • To tailor the content and information that we may send or display to you, to offer personalized help and instructions, and to otherwise personalize your experiences while using the Site.
  • For marketing and promotional purposes in accordance with applicable law. We may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products, events, or information we think may interest you. We also use the information that we learn about you to assist us in advertising our services on third party websites.
  • Establish and maintain communication with employees, investors and business partners. Further information on how Personal Information is used to manage our relationship with investors can be found in our Investor Privacy Notice.
  • To better understand how users access and use our Site, both on an aggregated and individualized basis, in order to improve our Site, respond to user desires and preferences, and for other research and analytical purposes.
  • To administer surveys and questionnaires, such as for market research or customer satisfaction purposes.
  • To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
  • Where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of any Site terms of service or this Policy or to otherwise protect our rights.
  • Where you apply for employment, in order to process your job application and for staffing, recruitment activities, and to maintain an inventory of candidates for current and future work opportunities
  • Fulfill any other purpose related to any of the above.

HOW WE SHARE YOUR PERSONAL INFORMATION

We share your information, including personal information, as follows:

  • Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. These service providers include entities that host our Site, manage our database of customers, analyze visitor traffic, display advertisements, and send emails on our behalf.
  • Other Third Parties. We share information with third parties on an anonymous or aggregated basis such that any individual would not be able to be identified and no Personal Information is shared. We remove personal identifiers from your information and maintain and use it in an aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information.
  • In the context of a transaction. We may disclose the information in the context of a business transaction, in connection with the proposed or actual financing, securitization, insuring, sale, assignment, or other disposal of all or part of Georgian, or our business or assets, for the purposes of evaluating and/or performing the proposed transaction. 
  • To meet legal, regulatory, insurance, audit and security requirements. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.

We will retain your Personal Information only for a time and to the extent necessary for the purposes for which it was collected as described in this Policy and for reasonable backup, archival, audit, or other similar purposes, subject to any retention periods that may apply pursuant to applicable law.  Once we no longer need to keep your Personal Information, it will be destroyed or anonymized in accordance with best practices and legal requirements.

INTERNATIONAL STORING AND TRANSFER OF PERSONAL INFORMATION

In order for us to provide our Services, information may be processed by us or by our third-party service providers outside of your jurisdiction of residence, including in other Canadian provinces or in the United States. Please note that the privacy laws in such jurisdictions may differ from those in your jurisdiction. We will take reasonable measures to ensure that your personal information is adequately protected, including by requiring our service providers comply with applicable privacy and data protection laws, and implementing contractual clauses that ensure the protection of your privacy rights, as applicable. 

By using our Services and accessing the Site, you consent to such international storage and transfer. 

COOKIES AND BEHAVIOURAL ADVERTISING

When you visit our Site, we use cookies and similar technologies to collect information about your visit to our Site to remember your preferences and settings when you navigate through our Site. We use this information to do internal research on our users’ demographics, interests, and behaviour to better understand, protect and serve you and our community, and to improve our services. We use both session and persistent cookies. A “session cookie” expires immediately when you end your session (i.e. close your browser). A “persistent cookie” stores information on the hard drive so when you end your session and return to our Site at a later date, the cookie information is still available. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on a computer.

We also use Google Analytics to better understand who is using our Site, and how people are using it. Please see http://www.google.com/policies/privacy/partners/ for information about how Google Analytics uses this information. Google may track your activity over time and across websites. Once again, such information is used to target advertisements and content that may be of interest to you, and also to provide statistical insight through features such as Google Analytics and Google Ads. 

As described above, we can use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.  For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.  Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/.

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking (e.g., by disabling cookies). Many web browsers allow you to manage your preferences. You can set your browser to refuse cookies or delete certain cookies. You may be able to manage other technologies in the same way that you manage cookies using your browser’s preference. In some instances, tracking tools used by third-party service providers may be disabled.

SECURITY

We aim to provide you with a safe experience. We have in place physical, electronic, technological, and organizational safeguards that are designed to protect the security and privacy of your Personal Information against loss, theft, and unauthorized access, disclosure, copying, use or modification. These safeguards are appropriate with regards to the nature and sensitivity of the Personal Information we collect and store. Please be aware that despite our efforts, no data security measures can guarantee security.  If you have a password to access certain sections of the Site, including the Investor Portal, or our Services, you are responsible for ensuring it is kept confidential. We ask that you inform us right away if you suspect your password has been compromised. 

We limit access to your Personal Information within Georgian and our affiliates to individuals on a need-to-know basis. We will also take reasonable measures to ensure all individuals who may access your information have been aware of their responsibilities in ensuring your Personal Information’s protection.

ACCESSING, CORRECTING AND DELETING PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes. At any time you can contact us to: stop receiving e-mails from us; review the Personal Information held by the Company; withdraw your consent to our use and disclosure of your Personal Information; request a list of third parties to which the Company may have provided your Personal Information; and amend your Personal Information, where possible, by writing to us at the address provided below.  Before providing you with access to your information, we may ask you for specific information to help us confirm your identity and right of access, and to provide you with the personal information we hold about you, or to make the requested changes.

We may not accept a request to change information if we believe that the change would violate a law or legal requirement; as such, we may continue to collect, use, and disclose your Personal Information as may be required to provide you with the Site, and to the extent that we are contractually obligated to do so or as necessary to enforce any contractual obligations you may have with us. 

Note that if you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your Personal Information, your experience in accessing the services and functionalities provided by the Site may be affected. We will explain the consequences of deletion at that time to assist you in your decision.

You can always unsubscribe from receiving promotional e-mails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional Company e-mail from us or by emailing info@georgian.io with the subject line: Opt-out. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.

LINKS TO OTHER SITES

We provide links on our Site to other, third-party sites we think you will find useful or interesting. These sites operate independently of us and have established their own privacy and security policies. Any personal information you provide on linked pages or other sites is provided directly to that third-party and subject to that third-party’s privacy policy. We strongly encourage you to review these policies at any site you visit. This Policy does not apply to such linked pages or other sites, and we are not responsible for the content or practices of any linked websites which are provided solely for your convenience.

CHANGES

We may update this Policy from time to time to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. Any changes will be communicated to you via email or notice on our Site.

RESIDENTS OF THE EUROPEAN ECONOMIC AREA

If you are a resident of the European Economic Area, you may also (depending on the applicable legislation) be entitled to:

  • The right to access – You have the right to request copies of your Personal Information. The first copy will be provided to you for free, however, we may charge you a reasonable fee for any additional copies.
  • The right to rectification – You have the right to request that we correct any Personal Information you believe is inaccurate. You also have the right to request that we complete the Personal Information you believe is incomplete.
  • The right to erasure – You have the right to request that we erase your Personal Information, under certain conditions.
  • The right to restrict processing – You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
  • The right to object to processing – You have the right to object to our processing of your Personal Information, under certain conditions.
  • The right to withdraw consent – You have the right to withdraw your consent at any time should the processing of your Personal Information be based on consent. We may, however, continue processing your Personal Information without your consent in accordance with applicable laws.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we will respond to you within a reasonable delay, in accordance with applicable laws. If you would like to exercise any of these rights, please contact us at our Privacy Officer’s contact details below. 

We process Personal Information for the purposes set out in this Policy, as described above. Our legal basis to process Personal Information includes processing that is: necessary for the performance of any agreement between you and Georgian (for example, to provide you with the Services); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you and to improve the Site and our Services); and based on your consent (for example, to communicate with you about our products and services and provide you with marketing information), which may subsequently be withdrawn at any time (by emailing privacy@georgian.io) without affecting the lawfulness of processing based on consent before its withdrawal.

In some instances, you may be required to provide us with Personal Information for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Site.

Our personnel and some of the third parties to whom we disclose Personal Information can be located in countries outside of the European Economic Area (“EEA”), including in countries that may not provide the same level of data protection as your jurisdiction. We take appropriate steps to ensure that recipients of your Personal Information are bound to duties of confidentiality and, where required under law, we implement measures such as standard data protection contractual clauses to ensure that any transferred Personal Information remains protected and secure. A copy of these clauses can be obtained by emailing privacy@georgian.io.

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, if you consider that our processing of your Personal Information infringes applicable law.

RESIDENTS OF CALIFORNIA

If you are a resident of California, you have the rights set forth in this section. If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@georgian.io.

Access

You have the right to request certain information about our collection and use of your Personal Information over the past 12 months, including the:

  • Categories of Personal Information that we have collected about you.
  • Specific pieces of Personal Information that we have collected about you.
  • Categories of sources from which that Personal Information was collected.
  • Business or commercial purpose for collecting your Personal Information.
  • Categories of third parties with whom we have shared your Personal Information.
  • Categories of Personal Information shared with third parties for a business purpose over the past 12 months, if applicable.

Deletion

You have the right to request that we delete the Personal Information that we have collected about you, subject to certain exceptions under the California Consumer Privacy Act (“CCPA”): for example, we may need to retain your Personal Information to provide you with the Site or Services or complete an other action you have requested, or if deletion of your Personal Information involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Information we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Information, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Exercising Your CCPA Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Information or are an agent authorized by that person, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You may submit a Valid Request by emailing us at privacy@georgian.io.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. 

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

We Do Not Sell Your Personal Information

We will not “sell” your Personal Information, as that term is defined in the CCPA, and have not done so over the last 12 months. We also do not sell the Personal Information of minors under 16 years of age.

Personal Information Sharing Opt-Out and Opt-In

Under the CCPA, California residents have certain rights when a business “shares” Personal Information with third parties for purposes of cross-contextual behavioral advertising. We will not share your Personal Information for cross-contextual behavioral advertising, and have not done so over the last 12 months. To our knowledge, we do not share the Personal Information of minors under 16 years of age for purposes of cross-contextual behavioral advertising.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not deny you access to our Site or provide you a lower quality of services if you exercise your rights under the CCPA. If you have any questions about this section or whether any of the above rights apply to you, please contact us at privacy@georgian.io.

AGE RESTRICTION

The Site is not intended for use by individuals under the age of sixteen (16). Georgian does not knowingly collect or use any Personal Information from any individuals under the age of sixteen (16). If we become aware that we have unknowingly collected Personal Information from an individual under the age of sixteen (16), we will make commercially reasonable efforts to delete such Personal Information from our database. 

CHANGES

If this Policy changes in the future, we will post an updated version on our Site. We recommend that you check this Site periodically in order to review our current Policy. You can tell if this Policy has changed by checking the date that appears at the bottom of this Policy. If you continue to use our Site after the Policy has changed or notice of the change has been given, you will be deemed to have accepted such changes.

QUESTIONS OR COMMENTS

If you have any questions or comments or wish to make a complaint about this Policy, please feel free to contact our Chief Compliance Officer/Privacy Officer by courier or by the mail, at 2 St Clair Ave West, Suite 1400, Toronto (Ontario) M4V 1L5 , by email at privacy@georgian.io or by calling us at (416) 868-9696. If you contact us about your Personal Information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

Effective Date: March 31, 2024