Last updated: September 1, 2020
what information we collect and why we collect it;
how we use that information; and he choices we offer, including how to access and update information.
Information we collect
We collect information in the following ways:
Information you give us
For example, information that you provide to us when contacting us for inquiries about potential investment, commercial opportunities or employment details if you send us a CV, resume or other details of your employment history in connection with an advertised job vacancy, signing up for our emails, or submitting a general inquiry regarding employment opportunities with us. When you do, you may provide us with your name, email address, telephone number and other details.
Information we get from your use of our Site
The Site is operated by or on behalf of CapitalG. We may collect information about when and how you use the Site. This information includes:
We may collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number).
When you use our Site, we may automatically collect and store certain information in server logs. This may include: details of how you used our SiteInternet protocol address device event information, such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL
cookies that may uniquely identify your browser
We may use technologies to determine your approximate location, including based on your IP address.
We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Cookies and similar technologies
We may use various technologies to collect and store information when you visit our Site, and this may include using cookies or similar technologies to identify your browser or device. You may set your browser to block all cookies, including cookies associated with this Site or to indicate when a cookie is being set by us. However, some website features or services may not function properly without cookies.
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. Other technologies are used for similar purposes as a cookie on other platforms where cookies are not available or applicable. Our Site sets cookies that last for varying times. Some last only for the duration of your web session and expire when you close your browser or exit the Site. Other cookies are used to remember you when you return to the Site and will last longer.
We use the information we collect to provide, maintain, protect and improve our Site; carry out due diligence for our business purposes; evaluate and monitor investments; help our portfolio companies grow their businesses; recruit and hire talent; comply with our legal obligations; and send you communications about news, events or other information we think may be of interest to you.
We may also use information collected from cookies and/or other technologies to:
facilitate your use of and improve overall quality of our Site and your user experience;
remember that you have visited us before. This means we can identify the number of unique visitors we receive;
customize elements of the promotional layout and/or content of the pages of the Site; and
collect statistical information about how you use the Site, so that we can improve the Site.
Transfer of personal information
Adhesion to the Privacy Shield Frameworks
To learn more about the Privacy Shield Framework, please visit https://www.privacyshield.gov/.
Accountability for onward transfers
We are responsible and remain liable for the processing of personal information we receive, under the Privacy Shield Framework, and subsequently transfer to a third party acting as an agent on our behalf.
With respect to personal information covered by our certification to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
We do not share personal information with companies, organisations and individuals outside of CapitalG unless one of the following circumstances applies:
With your consent
We may share personal information with companies, organisations or individuals outside CapitalG when we have your consent to do so.
For external processing
We may share personal information with companies, organisations or individuals outside CapitalG if we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to:
meet any applicable law, regulation, legal process or enforceable governmental request;
enforce applicable terms of service, including investigation of potential violations;
detect, prevent or otherwise address fraud, security or technical issues; or
protect against harm to the rights, property or safety of CapitalG, our users or the public, as required or permitted by law
Resolution of Privacy Shield queries and complaint mechanism
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. European Union (including the European Economic Area) and United Kingdom individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us. We have further committed to refer unresolved Privacy Shield complaints to JAMS. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield. The services of JAMS are provided at no cost to you. As further explained in the Privacy Shield Principles, a binding arbitration option may also be made available to you in order to address residual complaints not resolved by any other means.
Right of Access and updating your personal information
We aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).
Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
We explain the categories of information we collect and the sources of that information in “Information we collect.”
We explain how we use information in “How we use information we collect.”
We explain when we may share information in “How we share information we collect.” We do not sell your personal information.
The CCPA also provides the right to request information about how we collect, use, and disclose your personal information. And it gives you the right to access your information and request that we delete that information. Finally, the CCPA provides the right to not be discriminated against for exercising your privacy rights.
You can submit a privacy right request by completing this form. We will verify your request by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly. If you have questions or requests related to your rights under the CCPA, you (or your authorized agent) can also contact CapitalG.
The CCPA requires a description of data practices using specific categories.
Categories of personal information we collect (1)
Identifiers, such as your name, phone number and unique device identifiers tied to the device or browser you use to visit the Site
Parties with whom information may be shared (1)
Categories of personal information we collect (2)
Professional or employment-related data, such as your resume or other employment history information.Geolocation data, such as approximate location determined by IP address.Internet or other electronic network activity information, such as your interactions with our Site.
Parties with whom information may be shared (2)
Law enforcement or other third parties, for the legal reasons described in Sharing your information.
We work hard to protect our Site and any information that we hold from unauthorized access or unauthorized alteration, disclosure or destruction. In particular:
We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
We restrict access to personal information to CapitalG employees, contractors, service providers and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.