Privacy Policy

Our commitment to privacy

Your privacy is important to GLP Capital Partners Limited and its affiliates (together, “GCP,” “our,” “us” or “we”). To better protect your privacy, we are providing information explaining our online information practices. This website privacy policy (this “Privacy Policy”) describes how we gather and use personal information and personal data of visitors to this website and the online portals that we operate and which refer to this Privacy Policy (together, the “website”). Please read this Privacy Policy carefully. This Privacy Policy constitutes a legally binding agreement between GCP and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, this Privacy Policy, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree with any of the terms and conditions contained in this Privacy Policy, please do not access or otherwise use this website.

Visitors that are residents of California should also refer to our California Website Privacy Policy, which supplements this Privacy Policy, below.

Individuals that are located in the UK, European Union or the European Economic Area should refer to our EU and UK Website Privacy Policy below, which applies to our processing of your personal data in place of this Privacy Policy if and to the extent that the GDPR (as defined in the EU and UK Website Privacy Policy) applies to such processing.

Individuals that are based in Japan should refer to our Japan Website Privacy Policy below, which supplements this Privacy Policy, below.

Individuals that are based in Vietnam should refer to our Vietnam Website Privacy Policy below, which applies to our processing of your personal data in place of this Privacy Policy.

Individuals that are based in China (excluding the Hong Kong Special Administrative Region (“Hong Kong”)) should refer to our China Website Privacy Policy below, which applies to our processing of your personal data in place of this Privacy Policy.

Individuals that are based in Hong Kong should refer to our Hong Kong Website Privacy Policy below, which supplements this Privacy Policy, and applies to our collection, use, holding and processing of your personal data if and to the extent that the PDPO (as defined in the Hong Kong Website Privacy Policy) applies.

Individuals that are based in Singapore should refer to our Singapore Website Privacy Policy below, which supplements this Privacy Policy.

The information we collect and how we use it

We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, GCP collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (“IP”) addresses. GCP generally does not, however, collect any other personally identifiable information / personal data such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page or is required to provide any such information to access restricted areas of our website (such as providing access credentials for an investor portal). To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for GCP’s business purposes but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to GCP, you consent to GCP’s use of such personally identifiable information for the purposes described in this Privacy Policy. We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares. Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.

Capacity

You represent to GCP that you have the authority to visit this website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

Cookies

Information regarding how you access this website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences. You may access any personally identifiable information we have about you by contacting us at compliance@gcp.com.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

Notification of changes

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review this Privacy Policy regularly. If we decide to change this Privacy Policy, we will post those changes so our users are always aware of what personally identifiable information / personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of this Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy constitutes your acceptance of, and agreement to be bound by, such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

Miscellaneous

The provisions in our Terms of Use are hereby incorporated by reference.

California Website Privacy Policy

This California Website Privacy Policy supplements the Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

What does this website privacy policy apply to?

This California Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

What information do we collect about you?

We collect limited types of personal information through our website, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. In particular, we collect or have collected the following categories of personal information from individuals within the last twelve (12) months:

Category	Examples	Collection Information
A. Identifiers.	First name, last name, email address, and organization.	If you submit an inquiry via our “Contact Us” form on the Website
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	First name, last name, city, state or province, and country.	If you submit an inquiry via our “Contact Us” form on the Website
C. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	As necessary to improve Website performance, as noted in our Cookies Notice.
D. Professional or employment-related information.	Current or past job history.	Via the third-party application tracking system in our Careers page.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

We do not collect or use sensitive personal information other than:

To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
As reasonably necessary and proportionate to ensure the physical safety of natural persons;
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us); and
To perform services on behalf of our business

How do we obtain your personal information?

In connection with forming and operating our Website, we may collect and maintain your nonpublic personal information from the following sources:

Information from your communications with us in connection with this Website, including any update notices provided by you.
Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

How do we use your personal information?

We will use your personal information for one or more of the following business or commercial purposes (as such term is used in the CCPA):

To fulfill or meet the reason you provided the information.
To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
To keep a record of your relationship with us.
Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
To audit and verify the quality and effectiveness of our services and compliance.
To maintain the safety, security, and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
As needed to comply with U.S., state, local and non-U.S. laws, rules and regulations, including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

We do not collect or use sensitive personal information other than to perform the services, or provide any goods, as would reasonably be expected by an average consumer who requests those goods or services.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Who do we disclose your personal information to?

We do not sell any of the personal information we collect about you to third parties.

We do not sell or share (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties. We have not in the last 12 months, sold or shared any personal information collected to third parties.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

We disclose, or, within the last twelve (12) months, have disclosed each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “WHAT INFORMATION DO WE COLLECT ABOUT YOU?” only for those purposes set forth above in “HOW DO WE USE YOUR PERSONAL INFORMATION?”

How do we keep your personal information secure?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

Your rights under the CCPA

Deletion rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and access rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you. Such information includes:

the categories of personal information we collected about you;
the categories of sources from which the personal information is collected;
our business or commercial purpose for collecting such personal information;
the categories of third parties with whom we share the personal information;
the specific pieces of personal information we have collected about you; and
whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

Correction right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

No discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to exercise your rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information and our privacy policy and practices, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: (888) 214-2799.

Submit a request online using the following online form: Contact

Email us at the following email address: compliance@gcp.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request. We will inform you in writing if we cannot meet that timeline. But in certain cases, additional time might be required. Please contact us at the email address above with any questions about this California Website Privacy Policy.

EU and UK Website Privacy Policy

Our commitment to privacy

This EU and UK Website Privacy Policy describes how we gather and use personal data through this website, our online investor portal, as well as through other electronic communications (e.g., emails) between us and you (together, the “website”), as applicable, in each case, from persons that are located in the United Kingdom (“UK”), the European Union (“EU”) or the European Economic Area (“EEA”). This EU and UK Website Privacy Policy applies in place of the Privacy Policy of GCP above with respect to such UK, EU and EEA users, as applicable, to the extent that the GDPR (as defined below) applies to such processing. Please read this EU and UK Website Privacy Policy carefully.

For the purposes of the General Data Protection Regulation 2016/679 and all laws implementing such regulation, including as such regulation forms part of the laws of England and Wales, Scotland and Northern Ireland by virtue of the European Union (Withdrawal) Act 2018 (together, the “GDPR”), GCP is a controller of any personal data collected or processed by us in respect of visitors to this website, our online investor portal, as well as through other electronic communications. If you have any questions regarding our use of your personal data, or this EU and UK Website Privacy Policy, please contact us at compliance@gcp.com.

We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, GCP collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (“IP”) addresses. GCP generally does not, however, collect any other personal data such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us (including via telephone, post, email or our “Contact” page) or is required to provide any such information to access restricted areas of our website (such as providing access credentials for an investor portal). We rely on various legal bases under the GDPR in order to process your personal data, including our legitimate interests, contractual necessity and as required by applicable law. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.), nor do we collect any information about criminal convictions and offences.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information may mean that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Further information about the legal basis under which we process your personal data is included in the section headed “WHY WE USE YOUR PERSONAL DATA.”

You do not need to take any action as a result of this EU and UK Website Privacy Policy, but you do have certain rights as described below in the section headed “YOUR RIGHTS.”

How we obtain your personal data

Information that we collect through your use of the website and portals and information that you provide to us

We collect your personal data when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal data via online form, email, post, telephone and this website and when you log in to the investor online portal.

Information provided by third parties or publicly available sources

We also process information in relation to individuals and representatives of companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).

Why we use your personal data

To the extent that we collect or you provide us with any personal data, through or in connection with this website (e.g., via the online “Contact Us” form) or an investor online portal, we may use such information for the following purposes:

Purpose	Legal basis
To provide you with the services or products you have requested.	Contractual necessity
To keep a record of, and manage, your relationship with us, including responding to any queries submitted via the online “Contact Us” form.	Legitimate interest
To verify your identity.	Legal requirement
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.	Legitimate interest
Fraud and abuse prevention.	Legitimate interest
Litigation management and conducting internal audits and investigations.	Legitimate interest
To administer and protect our business and this website.	Legitimate interest
To make suggestions and recommendations to you about goods or services that may be of interest to you.	Legitimate interest

No automated decision-making, including profiling, is used by us when processing your personal data.

Marketing

We may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to or opt-out of receiving any such direct marketing communications at any time by contacting us at kallen@gcp.com.

Disclosure and transfer of personal data

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this website, any online portal or via any other electronic communication; any such transmission of information or data by you is at your sole risk.

Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including online portal, data hosting and other IT service providers. We seek to ensure that anyone who provides a service to, or for us, involving personal data enters into an agreement with us and meets our standards for data security. To the extent your personal data is transferred to countries outside of the UK, EU and EEA, such transfers will only be made in accordance with the GDPR. For further information about the safeguards/derogations used, please contact us at compliance@gcp.com.

In addition, we reserve the right to disclose your personal data as required by applicable law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the prospective or new owner of the relevant business and their advisors on the basis of our legitimate interest.

Security and retention of personal data

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EU and UK Website Privacy Policy, unless a longer retention period is required by applicable law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact us at compliance@gcp.com.

Capacity

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that information.

Cookies

Information regarding how you access this website or relevant online portal (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website or relevant online portal, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences. For further information about our use of cookies and similar technologies, and to exercise your rights to opt-in or out of the use of such technologies, please see our Cookie Notice.

Your rights

You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact us at compliance@gcp.com. Your rights in respect of the personal data processed by us under this EU and UK Website Privacy Notice are:

Access: You have the right to ask for a copy of the personal data that we hold about you free of charge; however, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
Correction: You may notify us of changes to your personal data if it is inaccurate or it needs to be updated.
Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it. Please note that this may not always be possible or required by the GDPR (for example, due to legal obligations).
Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against applicable law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
Object: You have the right to object to our processing of your personal data where our processing is based for direct marketing or based on our legitimate interests.
Portability: If you wish to transfer your personal data to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
Withdrawal of consent: If you previously gave us, and we rely on, your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Notification of changes

We reserve the right to amend this EU and UK Website Privacy Policy from time to time by updating this EU and UK Website Privacy Policy. If we decide to change our EU and UK Website Privacy Policy, we will post those changes so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use personal data only in accordance with the EU and UK Website Privacy Policy.

Contact us

If you have any queries or comments on this Privacy Policy or the use of your personal data, or would like to inquire, correct or update any of your personal data provided to us, please contact our Data Protection Officer at compliance@gcp.com.

Complaints

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.

Japan Website Privacy Policy

This Japan Website Privacy Policy supplements the Website Privacy Policy with respect to specific disclosures required under Act on the Protection of Personal Information (Act No. 57 of May 30, 2003, as amended, the “PIPA”). This supplement is only relevant to you if you are located in Japan as determined in accordance with the PIPA. Information required to be disclosed under the PIPA regarding the collection of personal information that is not set forth in this Japan supplement is otherwise set forth in the Website Privacy Policy.

Joint-use of Personal Information

GCP may share your personal information that you submit to us via our “Contact” page with our affiliates in Japan such as GLP Capital Partners Inc. for the purposes described in this Privacy Policy (the “Joint-use of Personal Information”). GCP will be primarily responsible for the Joint-use of Personal Information.

How do we keep your personal information secure?

Contact us

For any requests relating to the exercise of your rights under the PIPA (i.e. request for correction, disclosure and deletion), or questions regarding our processing of your personal information and our privacy policy and practices, please email us at compliance@gcp.com.

Vietnam Website Privacy Policy

Our commitment to privacy

Your privacy is important to GCP. To better protect your privacy, we are providing information explaining our online personal data processing practices.

This Vietnam Website Privacy Policy describes how we gather and use personal data through this website, our online investor portal, as well as through other electronic communications (e.g., emails) between us and you, as applicable, in each case, from persons that are located in Vietnam. This Vietnam Website Privacy Policy applies in place of the Privacy Policy of GCP above with respect to such Vietnamese users. Please read this Vietnam Website Privacy Policy carefully. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, this Privacy Policy, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree with any of the terms and conditions contained in this Privacy Policy, please do not access or otherwise use this website.

You do not need to take any action as a result of this Vietnam Website Privacy Policy, but you do have certain rights as described below in the section headed “YOUR RIGHTS.”

The information we collect

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, etc.), nor do we collect any information about criminal convictions and offenses.

How we obtain your personal data

We collect your personal data when you decide to interact with us in connection with this website and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal data via online form, email, post, telephone, and this website and when you log in to the investor online portal. We may combine personal data that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

How we use your personal data

We will use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. To the extent that we collect or you provide us with any personal data, through or in connection with this website (e.g., via the online “Contact Us” form) or the investor online portal, we may use such information for the following purposes:

To provide you with the services or products you have requested.
To keep a record of, and manage, your relationship with us, including responding to any queries submitted via the online “Contact Us” form.
To verify your identity.
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.
Fraud and abuse prevention.
Litigation management and conducting internal audits and investigations.
To administer, support, develop, improve and protect our business and this website.
To maintain the safety, security, and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
To audit and verify the quality and effectiveness of our services and compliance.
To provide you with direct marketing communications to keep you informed of our products and services in which you might be interested where we have obtained your prior consent and complied with relevant Vietnamese requirements to conduct such activities . You may opt-in to receiving any such direct marketing communications at any time by contacting us at kallen@gcp.com.
To comply with applicable law or the request of the competent authority.

If we require your personal data in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information may mean that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Cookies

Information regarding how you access this website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences. You may access any personally identifiable information we have about you by contacting us at compliance@gcp.com.

Information retaining period

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Vietnam Website Privacy Policy unless a longer retention period is required by applicable law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact us at compliance@gcp.com.

Persons or organizations who can approach personal data

Your personal data will be shared with and processed by our employees, agents, contractors, affiliates and certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including data hosting and other IT service providers. By entering and using this website, you consent for us to share your personal data with our employees, agents, contractors, affiliates and certain service providers, and agree that they can process your personal data (including collection, recording, analysis, storage, change, disclosure, grant of access, retrieval, collection recovery, encryption, decryption, copying, transfer, deletion, destruction and other related actions), all of which are for the purposes set out in this Privacy Policy. We seek to ensure that anyone who provides a service to, or for us, involving personal data enters into a confidentiality agreement with us and meets our standards for data security. Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.

To the extent your personal data is transferred to countries outside of Vietnam, such transfers will only be made with your consent and in accordance with the applicable laws of Vietnam. For further information about the safeguards/derogations used, please contact us at compliance@gcp.com.

Security and retention of personal data

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Capacity

You represent to GCP that you have the authority to visit this website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that information.

Your rights

Access: You have the right to ask for a copy of the personal data that we hold about you free of charge; however, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
Correction: You may notify us of changes to your personal data if it is inaccurate or it needs to be updated.
Deletion: If you think that we should not be holding or processing your personal data anymore, you may request that we delete it.
Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against applicable law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
Object: You have the right to object to our processing of your personal data.
Withdrawal of consent: If you previously gave us, and we rely on, your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

Notification of changes

We reserve the right to amend this Vietnam Website Privacy Policy from time to time by updating this Vietnam Website Privacy Policy. If we decide to change our Vietnam Website Privacy Policy, we will post those changes so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use personal data only in accordance with the Vietnam Website Privacy Policy.

Contact us

If you have any questions or concerns about this Vietnam Website Privacy Policy or our privacy practices, please contact us at compliance@gcp.com.

China Website Privacy Policy

This China Website Privacy Policy supplements the Website Privacy Policy and will apply to our processing (referring to collecting, storing, processing, using, sharing, disclosing and deleting, etc.) of personal information in Mainland China (“China” or “Chinese”) or, to the extent that any Chinese laws and regulations (including the Personal Information Protection Law, Data Security Law, Civil Code, Cybersecurity Law, and other relevant laws, regulations, regulatory requirements and national standards, collectively “Applicable Legal Requirements”) apply, our processing of personal information outside of China. This China Website Privacy Policy does not replace the global privacy policy. In case of any inconsistency between China Website Privacy Policy and other parts of the Website Privacy Policy, this China Website Privacy Policy prevails. To the extent that this China Website Privacy Policy or any other part of the Website Privacy Policy is inconsistent with Applicable Legal Requirements in respect of a particular China-related matter, they shall be deemed amended to the extent required to comply with Applicable Legal Requirements.

Requirement to Provide your Personal Information

From time to time, we may request you to provide your personal information in connection with the business purposes listed below. Where required by Applicable Legal Requirements, we will obtain your separate consent or notify you in writing as applicable before processing your personal information for any such particular business purpose. If you fail to provide such personal information, we may be unable to provide you with our products or services (or any part thereof), or comply with Applicable Legal Requirements.

To fulfill or meet the reason you provided the information.
To provide, support, personalize, develop and improve our Website and the products and services that we offer and notify you about changes to our products and services.
To provide you with support and to communicate with you, including responding to requests for information submitted by you through our Website.
To keep a record of your relationship with us.
Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
To audit and verify the quality and effectiveness of our services and compliance.
To maintain the safety, security, and integrity of our Website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
As needed to comply with Applicable Legal Requirements, including responding to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
To keep you informed of our products and services.

Sensitive Personal Information

Personal information that, once leaked or illegally used, may easily cause infringement upon the human dignity or harm to personal or property safety of a natural person is defined as sensitive personal information in accordance with Applicable Legal Requirements. For achieving the purpose specified in the Website Privacy Policy, we may collect certain types of sensitive personal information only when permitted or required by Applicable Legal Requirements, such as financial information including payment information and related bank details, etc. for the fulfillment of your order of our products or services (or any part thereof). Our processing of your sensitive personal information will comply with Applicable Legal Requirements including the enhanced protection measures, and the separate consent you give us to such processing.

Processing Personal Information about Children

Personal information of children under the age of 14 may be considered as sensitive personal information and thus specially protected under Applicable Legal Requirements. Our Website, our products and services do not target children, and we will not intentionally collect personal information from children. If you find that we accidentally collect personal information of your children under the age of 14, please contact us via the contact information stated below in this China Website Privacy Policy to request us to delete or express consent to our collection of personal information of your children.

Outsourcing of Data Processing and Offshoring

To the extent permitted by Applicable Legal Requirements, the processing of your personal information may be performed by (i) relevant entities in GCP (wherever located); or (ii) service providers of relevant entities in GCP (wherever located) for any of the purposes listed in this China Website Privacy Policy. You authorize us to transfer your personal information to such entities and service providers as we are permitted to do so under Applicable Legal Requirements or otherwise allowed by regulators, and as we deem appropriate. Where required by Applicable Legal Requirements, we will obtain your separate consent before we outsource the processing of your personal information or transfer your personal information to an offshore entity, and perform any other obligations with respect to the cross-border transfer of personal information in accordance with Applicable Legal Requirements.

Your Rights Relating to Personal Information

You have the right to check with us whether we hold your personal information and to check and make a copy of personal information you have provided to us.

You have the right and obligation to update your personal information with us to ensure all information be accurate and up-to-date. You have the right to request us to provide convenience for you to update your personal information with us and to correct any of your personal information that is inaccurate.

You have the right to request us to delete or otherwise properly dispose of your personal information that is beyond retention period in accordance with the Applicable Legal Requirements, this China Website Privacy Policy, and other agreement between you and us.

You have the right to request an explanation of this China Website Privacy Policy or other parts of the Website Privacy Policy.

Nothing in this China Website Privacy Policy shall limit the rights you should have as a personal information subject under Applicable Legal Requirements. Notwithstanding the above, these rights may be subject to certain exceptions, and we are only required to honor rights to the extent that they have been granted to you and apply to you under Applicable Legal Requirements.

Notifications

We cannot guarantee the absolute security of any information or data you provide online. In the event of a security incident, we will take mitigation measures in accordance with our incident response plan and report to competent regulators in China as required by Applicable Legal Requirements. In the event of a security incident affecting your personal information, we will notify you to the extent required by Applicable Legal Requirements through email, correspondence, telephone, push notification or other means. If you think your data is the subject of a security incident and we have not notified you, or if you are concerned about the security of your data, you may contact us via the contact details listed below in this China Website Privacy Policy.

Contact us

Please contact us at compliance@gcp.com if you intend to inquire, correct or update any of your personal information provided to us, or to exercise any other statutory rights related to your personal information.

Languages

This China Website Privacy Policy is prepared in both Chinese and English. If any discrepancy exists between the two versions, the English version shall prevail.

Hong Kong Website Privacy Policy

Our commitment to privacy

The Hong Kong privacy policy statement and personal information collection statement as set out herein (“Hong Kong Website Privacy Policy”) describe how we collect, hold, process and use personal data that you may provide to us on this website and our online investor portal. This Hong Kong Website Privacy Policy supplements the Privacy Policy of GCP above, and applies where:-

your personal data is controlled by our Hong Kong affiliates;
any part of the data cycle (i.e. collection, holding, processing, and use) is controlled by us in, or from, Hong Kong; or
the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO”) is otherwise applicable.

Please read this Hong Kong Website Privacy Policy carefully. To the extent there is any conflict between the Privacy Policy of GCP above and the Hong Kong Website Privacy Policy, this Hong Kong Website Privacy Policy prevails.

Personal data we collect

We may collect various types of information from users of this website. For example, GCP’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (“IP”) addresses.

GCP generally does not, however, collect any other personal data such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page or through our investor online portal.

Further information about the legal basis under which we process your personal data is included in the section headed “WHY WE USE YOUR PERSONAL DATA.”

How we obtain your personal data

Information that we collect through your use of the website and portals and information that you provide to us

Information provided by third parties or publicly available sources

We also process information in relation to individuals and representatives of companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data may be provided to us by third parties involved in that potential transaction (including the target of any investment).

Why we use your personal data

To the extent that we collect or you provide us with any personal data, through or in connection with this website (e.g., via the online “Contact Us” form) or the investor online portal, we may use such information for the following purposes:

To provide you with the services or products you have requested.
To verify your identity as part of the initial and on-going Know-Your-Client (KYC) due diligence process and otherwise for the purposes of complying with anti-money laundering laws and regulations which we are subject to.
To provide you with direct marketing communications and to make suggestions and recommendations to you about goods or services that may be of interest to you.
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment.
To keep a record of, and manage, your relationship with us, including responding to any queries submitted via the online “Contact Us” form.
To administer and protect our business and this website.
For recruitment and human resource management.
For fraud and abuse prevention.
For litigation management and conducting internal audits and investigations.
For engagement and management of our professional relationships with contractors and their staff.
To compile statistics about our user or customer to analyze site usage or aggregated consumer behavior.
To comply with any applicable laws, rules, regulations, court orders or the requests or requirements of any regulatory body.
To defend our rights or to participate in any legal or administrative proceedings.
To implement any other purposes relating to the above.

Direct marketing

We may use your personal data, such as your name, telephone number, email address, and correspondence address for the purpose of sending you direct marketing communications and to keep you informed of our products and services in which you might be interested. We will comply with the PDPO and any other applicable laws, and if required, obtain your prior consent before we use your personal data for direct marketing activities.

If you do not wish your personal data to be used for the purposes of direct marketing activities, please send us an email at compliance@gcp.com and notify us that you do not wish your personal data to be used for such purposes. To ensure that your request can be processed quickly please provide your name and email address.

Transfer of personal data

Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including data hosting and other IT service providers. We seek to ensure that anyone who provides a service to, or for us, involving personal data enters into an agreement with us and meets our standards for data security.

Disclosure of personal data

We also reserve the right to disclose and transfer your personal data (whether in Hong Kong or elsewhere) in order to comply with applicable laws and regulations and when we believe that disclosure is necessary or advisable to protect our rights and/or comply with a judicial proceedings, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us.

Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the prospective or new owner of the relevant business and their advisors.

Security

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies to protect the personal data we hold against loss, unauthorized access, use, modification or disclosure.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention of personal data

We will keep your personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, and for the purposes of satisfying our legal, accounting or compliance-related requirements after which it will be destroyed without further notice to you. For further information about how long we will keep your personal data, please contact us at compliance@gcp.com.

Capacity

Cookies

Should you prefer, you can change your browser settings to block the use of cookies. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

Access and correction of personal data

Under the PDPO, you have the right to ascertain whether we hold your personal data, to obtain a copy of the data, and to correct any data that is inaccurate.

If you would like to request for access or correction of your personal data, or for information regarding policies and practices and kinds of data held by us, please contact us at compliance@gcp.com.

A reasonable fee may be charged to cover our costs in complying with your data access requests.

We may also need to request specific information from you to help us confirm your identity and ensure your right to access or correct your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Notification of changes

We reserve the right to amend this Hong Kong Website Privacy Policy from time to time by updating it. If we decide to change our Hong Kong Website Privacy Policy, we will post those changes so our users are always aware of what personal data we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected personal data in a manner different from that stated at the time it was collected, we will notify applicable users. We will use personal data only in accordance with the Hong Kong Website Privacy Policy.

Contact us

If you have any questions or concerns about this Hong Kong Website Privacy Policy or our privacy practices, please contact us at compliance@gcp.com.

Singapore Website Privacy Policy

This Singapore Website Privacy Policy supplements the Website Privacy Policy with respect to personal data that is collected, used, disclosed, and or processed by GCP in Singapore.

How we use your personal data

To provide you with the services or products you have requested.
To keep a record of, and manage, your relationship with us, including responding to any queries submitted via the online “Contact Us” form.
To verify your identity.
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to.
Fraud and abuse prevention.
Litigation management and conducting internal audits and investigations.
To administer, support, develop, improve and protect our business and this website.
To maintain the safety, security, and integrity of our website, products and services, databases, technology assets and business, including to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
To make suggestions and recommendations to you about goods or services that may be of interest to you.
Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
To audit and verify the quality and effectiveness of our services and compliance.
To provide you with direct marketing communications to keep you informed of our products and services in which you might be interested where we have obtained your prior consent. You may opt-in to receiving any such direct marketing communications at any time by contacting us at compliance@gcp.com.
To comply with applicable law or requests of relevant authorities.
Any such purpose(s) as notified to you at the relevant time when we collect your personal data.

Privacy Policy

Our commitment to privacy

The information we collect and how we use it

Capacity

Cookies

Notification of changes

Miscellaneous

California Website Privacy Policy

What does this website privacy policy apply to?

What information do we collect about you?

How do we obtain your personal information?

How do we use your personal information?

Who do we disclose your personal information to?

How do we keep your personal information secure?

Your rights under the CCPA

Contact us

EU and UK Website Privacy Policy

Our commitment to privacy

How we obtain your personal data

Why we use your personal data

Marketing

Disclosure and transfer of personal data

Security and retention of personal data

Capacity

Cookies

Your rights

Notification of changes

Contact us

Complaints

Japan Website Privacy Policy

Joint-use of Personal Information

How do we keep your personal information secure?

Contact us

Vietnam Website Privacy Policy

Our commitment to privacy

The information we collect

How we obtain your personal data

How we use your personal data

Cookies

Information retaining period

Persons or organizations who can approach personal data

Security and retention of personal data

Capacity

Your rights

Notification of changes

Contact us

China Website Privacy Policy

Requirement to Provide your Personal Information

Sensitive Personal Information

Processing Personal Information about Children

Outsourcing of Data Processing and Offshoring

Your Rights Relating to Personal Information

Notifications

Contact us

Languages

Hong Kong Website Privacy Policy

Our commitment to privacy

Personal data we collect

How we obtain your personal data

Why we use your personal data

Direct marketing

Transfer of personal data

Disclosure of personal data

Security

Retention of personal data

Capacity

Cookies

Access and correction of personal data

Notification of changes

Contact us

Singapore Website Privacy Policy

How we use your personal data

Contact us

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