Applicant and Talent Bank Privacy Notice

(Rev. January 2026)

About us

We are General Atlantic Service Company, L.P. Our principal place of business is at Park Avenue Plaza, 55 East 52nd Street, 33rd Floor, New York, NY 10055. We have a number of subsidiaries and offices located in various jurisdictions, details of which can be found on the General Atlantic website at https://www.generalatlantic.com/offices and the Actis website (https://www.act.is/contact/) (collectively, General Atlantic, we, us or our).

We are a data controller for the purposes of the applicable privacy laws in the jurisdictions in which we operate, including, but not limited to, the General Data Protection Regulation 2016/679 (GDPR), the UK GDPR and the UK Data Protection Act, the California Consumer Privacy Act of 2018 and any applicable national data protection acts (Data Protection Laws). This means in relation to the personal information you provide to us; we will determine why and how it is used.

This Applicant and Talent Bank Privacy Notice (the Notice) explains how General Atlantic processes and handles your personal information. This Notice applies to:

individuals who are being considered for a job or board appointment within General Atlantic or one of General Atlantic’s portfolio companies (Applicants); and
individuals who have previously applied for a job or board appointment within General Atlantic or one of General Atlantic’s portfolio companies that we have identified as having the qualifications and experience that make them a good fit (now or in the future) for a job or a board appointment within General Atlantic or one of General Atlantic’s portfolio companies (Former Applicants); and
contacts from our business dealings that we have identified as having the qualifications and experience that make them a good fit (now or in the future) for a job or a board appointment within General Atlantic or one of General Atlantic’s portfolio companies (Talent).

Applicants who choose not to proceed with their application, or are unsuccessful, become Former Applicants.

For information about how we collect information through our websites, cookies, web pixels and other similar automated technologies, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our Digital Properties), please refer to our General Privacy Notice on the General Atlantic website at https://www.generalatlantic.com/privacy-notice/.

If you reside in California, please refer to Personal Information Rights for Residents of California below.

Why are you receiving this information?

If you are an Applicant, you are receiving this Notice to explain how we process your personal information when considering your application for a job or board appointment within General Atlantic or one of General Atlantic’s portfolio companies.

If you are a Former Applicant or Talent, you are receiving this Notice to explain how we process your personal information because we have created a profile of you in the talent bank systems that we manage. The reason for this is that we believe you may be a good fit (now or in the future) for a job or a board appointment within General Atlantic or one of General Atlantic’s portfolio companies.

Deleting your Profile

If you do not want to have a profile in General Atlantic’s talent bank systems, and/or want us to stop contacting you about job or board appointment opportunities, you can let us know at any time by emailing us at [email protected]. We will delete your information from our talent bank systems and add you to a mailing suppression list to ensure that you are not contacted about opportunities in the future.

What personal information do we collect?

Personal information is information that either alone or in combination with other information can directly or indirectly identify you. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:

Identity and Contact Data, such as your first name, last name, title, date of birth, gender, unique personal IDs, social media handles, device identifiers, address, phone number, email and postal address.
Recruitment Data, such as CVs, copies of right to work/visa documentation, salary and other compensation, education, professional licenses, credentials, affiliations, references and other information provided as part of the application process.
Employment Data, such as employment contracts, consultancy agreements, job titles, work history, working hours, training records and professional memberships.
Communications Data which includes calls you make to us, correspondence or messages (including emails, SMS or chat or social media messages or comments) that you send to us.
Visit Data which includes information collected when you visit our office, such as security information and CCTV footage.
Interview Data which includes recordings of any interviews you conduct, provided you will be told prior to the interview being recorded.
Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences or behavior, including to assess the level of interest in our roles and positions based on frequency of visits and contact.
Other Data relating to your activities, interests or private life which you provide to us including where they are part of interactions with us or our employees, messages or conversations sent through our systems or networks, including gifts or hospitality that you receive where you provide details of them to us.
Sensitive Data, such as social security numbers, driver’s license, account log-in information, any data about religious, ideological, political or trade union views or activities, your health, private life, the intimate sphere or racial origin, (personal data which is also referred to as Special Category Data).

All the above categories of data are personal information.

How is this information collected

For Applicants and Former Applicants, we collect personal information about you through the application and recruitment process, either directly from you or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, or other background check providers, companies for whom you work, our portfolio companies, other organizations with whom you have dealings, government agencies, credit reporting agencies.

For Talent, we collect personal information about you through our business dealings with you and from professional social media networks such as LinkedIn or Xing. We may sometimes collect additional information from third parties including former employers, business partners, affiliated companies or other background check providers, companies for whom you work, our portfolio companies, other organizations with whom you have dealings, government agencies and credit reporting agencies.

Sensitive Data will only be collected by us if you have provided it to us directly with the exception of your political opinions which have public exposure which may be processed by General Atlantic based on the personal data having been made public by you and/or the personal information is necessary for reasons of substantial public interests or otherwise as permitted by law.

We may combine information that we receive from the various sources described in this Notice, including third party sources, and use and disclose the combined information for the purposes identified below.

How do we use your data and for what purpose?

We use and process your personal information for the purposes set out in the table below:

Purpose	Data Types	Legal Basis
Applicants
To process or respond to your application for a job or board appointment	Identity and Contact Data Recruitment Data Communications Data Employment Data Interview Data Other Data	Legitimate interests – necessary to review your application for a role.
To evaluate your qualifications and suitability for employment for a job or board appointment	Identity and Contact Data Recruitment Data Communications Data Employment Data Interview Data Other Data Inferences	Legitimate interests – necessary to review your qualifications for a role.
To communicate with you (including for the purpose of answering any questions you may have)	Identity and Contact Data Recruitment Data Communications Data Employment Data Interview Data Sensitive Data Inferences	Legitimate Interests – necessary to respond to you and answer your questions.
To comply with local laws and regulations, including requests from government or other public authorities, for pursuing legal rights and remedies, defending litigation, conducting audits and investigations, and complying with internal policies and procedures	Identity and Contact Data Recruitment Data Employment Data Interview Data Other Data Sensitive Data	Legitimate Interests – necessary to comply with our legal and regulatory obligations.
To ensure the security of our staff and our offices.	Identity and Contact Data Communications Data Visit Data	Legitimate Interests – necessary to ensure the security of our staff and our offices.
To track equality and diversity initiatives	Sensitive Data	To identify or keep under review the existence or absence of equality of opportunity or treatment between groups of people where we are permitted to do so by applicable law.
Former Applicants
To consider you for potential roles, opportunities or jobs at General Atlantic, or one or more of its portfolio companies or investment prospects – both now and in the future	Identity and Contact Data Recruitment Data Communications Data Employment Data Interview Data Other Data Inferences	Legitimate interests – necessary to assess your suitability for existing and future roles within General Atlantic or its portfolio companies.
To share contact details and other information to facilitate introductions with General Atlantic portfolio companies and investment prospects	Identity and Contact Data Recruitment Data Employment Data Other Data Inferences	Legitimate interests – necessary to assess your suitability for existing and future roles within General Atlantic or its portfolio companies.
To communicate with you (including for the purpose of answering any questions you may have)	Identity and Contact Data Communications Data	Legitimate Interests – necessary to respond to you and answer your questions.
To track equality and diversity initiatives	Sensitive Data	To identify or keep under review the existence or absence of equality of opportunity or treatment between groups of people where we are permitted to do so by applicable law.
To comply with local laws and regulations, including requests from government or other public authorities, for pursuing legal rights and remedies, defending litigation, conducting audits and investigations, and complying with internal policies and procedures	Identity and Contact Data Recruitment Data Employment Data Interview Data Other Data Sensitive Data	Legitimate Interests – necessary to comply with our legal and regulatory obligations.
To track equality and diversity initiatives	Sensitive Data	To identify or keep under review the existence or absence of equality of opportunity or treatment between groups of people where we are permitted to do so by applicable law.
Talent
To consider you for potential roles, opportunities or jobs at General Atlantic, or one or more of its portfolio companies or investment prospects – both now and in the future	Identity and Contact Data Recruitment Data Communications Data Employment Data Interview Data Other Data Inferences	Legitimate interests – necessary to assess your suitability for existing and future roles within General Atlantic or its portfolio companies.
To share contact details and other information to facilitate introductions with General Atlantic portfolio companies and investment prospects	Identity and Contact Data Recruitment Data Employment Data Other Data Inferences	Legitimate interests – necessary to assess your suitability for existing and future roles within General Atlantic or its portfolio companies.
To communicate with you (including for the purpose of answering any questions you may have)	Identity and Contact Data Communications Data	Legitimate Interests – necessary to respond to you and answer your questions.
To comply with local laws and regulations, including requests from government or other public authorities, for pursuing legal rights and remedies, defending litigation, conducting audits and investigations, and complying with internal policies and procedures	Identity and Contact Data Recruitment Data Employment Data Interview Data Other Data Sensitive Data	Legitimate Interests – necessary to comply with our legal and regulatory obligations.
To track equality and diversity initiatives	Sensitive Data	To identify or keep under review the existence or absence of equality of opportunity or treatment between groups of people where we are permitted to do so by applicable law.

General Atlantic does not collect or process Sensitive Data with the purpose of inferring characteristics about Applicants, Former Applicants or Talent. Sensitive Data may be held for statistical analysis and reporting to identify or keep under review the existence or absence of equality of opportunity or treatment between groups of people where we are permitted to do so by applicable law.

Before collecting and/or using any Sensitive Data we will establish a condition for processing or similar requirement which allows us to use that information. This exemption will typically be:

your explicit consent;
the establishment, exercise, or defense by us or third parties of legal claims; or
other uses allowed by applicable law including context specific exemptions provided for under applicable laws, such as the processing of Special Category Data for the purposes of substantial public interest (e.g. preventing or detecting fraud).

Who do we share your data with?

If you are an Applicant, your application is made available to General Atlantic group entities (our Affiliates) in other locations around the world to the extent legally permitted. Please see “Transferring information about you abroad” in the General Privacy Notice.

If you are a Former Applicant or Talent, your profile is made available to our Affiliates utilizing our talent bank systems to see to see if you are suitable for vacant roles. If your qualifications may be suitable for an open role, General Atlantic may contact you.

Who else might receive your personal information

We may share or disclose your personal data to third parties, including the categories of recipients described below:

Third-party service providers (Vendors), for example, to complete transactions and administer investments, host your data, to pay for services, analytics providers, for the purposes described above, and for security purposes. We aim to ensure our service providers implement appropriate privacy and security safeguards and enter into contracts that include data protection obligations. We conduct due diligence and ongoing monitoring of service providers. Where required by law, service providers must notify us of security incidents without undue delay, and in any event within mandatory timeframes.
Professional advisors such as lawyers and accountants, fund administrators, depositories, distributors, registered agents and other consultants and business partners (Professional Advisors). We may also disclose information to Professional Advisors where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process (Legal Authorities).
To the extent deemed necessary by General Atlantic for the purpose of this Notice, in particular, for security reasons or as required by mandatory laws and regulations.
Entities to which you have consented to the disclosure.
Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.

How long do we keep your personal information?

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Notice in accordance with our data retention policy.

You have control of your personal information and can request that it is deleted at any time by emailing [email protected]. To the extent that any of your personal information is incorrect or not required for the above purposes, you have the right to request correction, update, deletion or blocking of such data in accordance with applicable data protection laws.

When we have no ongoing legitimate business need or legal obligation to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), we will store your personal data securely and isolate it from further processing until deletion is possible.

Please note that General Atlantic also reserves the right, without notice or your consent, to remove or your delete your profile from our talent bank systems at any time.

Please email us at [email protected] with any queries relating your personal information or our personal information retention periods.

Data Security

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information. We implement technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, or disclosure. Where required by law, we will notify regulators and affected individuals of certain security incidents.

Updates to this Notice

We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by Data Protection Laws.

You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this notice.

What Rights Do UK/EEA/EU Residents Have?

Under the GDPR and the UK Data Protection Act, residents domiciled in the EU, EEA or the UK have certain rights with respect to their personal information. In particular, EU, EEA, and UK residents have the right to:

Request access to your personal information (commonly known as a subject access request). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal information in certain circumstances. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Request restriction of processing of your personal information.
Withdraw consent at any time where we are relying on consent to process your personal information. This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

UK residents further have the right to:

Complain to us about how we use your personal information.

Please email us at [email protected] to exercise your rights.

Where you exercise your right of access, exemptions (such as where disclosing your information would reveal legally privileged information or third-party personal data) may apply, meaning that you may not always receive all the personal information that we process about you. We consider and apply exemptions on a case-by-case basis.

If you are a UK resident exercising your right of access, please note that we are required to carry out a reasonable and proportionate search for your personal information when responding to your request.

We may contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex. In this case, we will notify you and keep you updated.

How to contact us

If you have any questions or concerns concerning this Notice, the way we process your personal data, or are a resident of India and wish contact our Grievance Officer please contact us at:

Email: [email protected]

Complaints

If you wish to make a complaint about how we have handled your personal information, please contact us at the details above and we will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal information in accordance with the law, you can escalate your complaint to the data protection authority in your jurisdiction, details of which can be found online. For the countries in which we have offices, we have set out the details and a link to the relevant data protection authorities and, where required to do so by local laws, provided a local point of contact, in the table below:

Country	Data Protection Authority Name and Details
Brazil	Autoridade Nacional de Proteção de Dados https://www.gov.br/anpd/pt-br
China	The Cyberspace Administration of China https://www.cac.gov.cn/
Egypt	Personal Data Protection Centre https://mcit.gov.eg/en
Germany	The Federal Commissioner for Data Protection and Freedom of Information https://www.bfdi.bund.de/EN/Home/home_node.html
Hong Kong	The Office of the Privacy Commissioner for Personal Data https://www.pcpd.org.hk/
India	The Ministry of Electronics and Information Technology https://www.meity.gov.in/
Japan Contact: Yuri Nagaki (Office Manager) Address: Actis Limited (Tokyo Branch) Marunouchi Nijubashi Building 3-2-3 Marunouchi Chiyoda-ku 100-0005	The Personal Information Protection Commission https://www.ppc.go.jp/en/
Kenya	Office of the Data Protection Commissioner https://www.odpc.go.ke/
Luxembourg	National Commission for Data Protection https://cnpd.public.lu/en.html
Mauritius	Data Protection Office https://dataprotection.govmu.org/
Mexico	Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales https://home.inai.org.mx/
Netherlands	The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) https://www.autoriteitpersoonsgegevens.nl/
Nigeria	The Nigeria Data Protection Commission https://ndpc.gov.ng/
Republic of Korea	The Personal Information Protection Commission https://www.pipc.go.kr/np/
Singapore	The Personal Data Protection Commission https://www.pdpc.gov.sg/
South Africa	The Information Regulator https://inforegulator.org.za/
Spain	Agencia Española de Protección de Datos https://www.aepd.es/
United Arab Emirates	Office of Data Protection https://www.adgm.com/
United Kingdom	Information Commissioner’s Office https://ico.org.uk/

Personal Information Rights for Residents of California

Data Subject Rights

If you live in California, you may have certain rights regarding personal data that you can exercise by emailing us at [email protected] or by calling (844) 470-0002:

Right to Know. You may have the right to request information about the categories of personal data we have collected about you, the categories of sources from which we collected the personal data, the purposes for collecting, selling, or sharing the personal data, and to whom we have disclosed your personal data and why. You may also request the specific pieces of personal data we have collected about you.
Right to Delete. You may have the right to request that we delete personal data that we have collected from you.
Right to Correct. You may have the right to request that we correct inaccurate personal data that we maintain about you.
Right to Opt Out of Profiling. You may have the right to opt out certain automated processing activities that are used to evaluate characteristics about you. We do not presently engage in such profiling.
Right to Limit Use and Disclosure of sensitive personal data. You may have the right to limit the use and disclosure of sensitive personal data.
Right to Opt Out of Sales, Sharing, and Targeted Advertising. You may have the right to opt out of selling, sharing, and targeted advertising. We do not knowingly sell data about minors under 18. You may exercise the Right to Opt Out of Sale, Sharing, and Targeted Advertising by accessing our Privacy Preference Center – Your Privacy Choices and selecting “Reject Optional Cookies” or by submitting a request by emailing us at [email protected] or by calling (844) 470-0002.

To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt- out preference signals at the browser level.

We will not discriminate against you for exercising your privacy rights.

Verification: To process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request.

For Requests to Opt-Out of Sale, Sharing, and Targeted Advertising and Requests to Limit Use and Disclosure of Sensitive personal data: We collect your name and email to locate you in our records.
For Requests to Know, Delete, and Correct: We collect information necessary to verify your identity and that you are a resident of California, including name, mailing address, email address, phone number, relationship to General Atlantic.

Authorized Agents: Authorized agents may exercise rights on your behalf by submitting a request by emailing us at [email protected] or by calling (844) 470-0002.

If you designate an authorized agent to submit a Request to Know, Delete, or Correct, we may seek additional information from the authorized agent or reach out to you directly to verify your identity or to confirm that you provided the authorized agent with permission to submit the request.
If you designate an authorized agent to submit a Request to Opt Out of Sale, Sharing, and Targeted Advertising, we may seek additional information directly from the authorized agent to process the request.

Additional Data Processing Disclosures

In addition to the disclosures above, this section provides supplemental information about how we process personal data.

Disclosure of personal data

Below please find a chart detailing the categories of personal data we collected and to whom it was sold, shared, or disclosed for a business purpose in the past 12 months.

*Categories of personal data We Collect*	*Categories of Third Parties to Whom We Disclose personal data for a Business Purpose*	*Categories of Third Parties to Whom Personal Data is Sold or Shared for Targeted Advertising*
Identity Data and Contact Data	Affiliates and subsidiaries Service providers Professional consultants Law enforcement, government agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure	Where collected for recruitment purposes, we do not sell or share this data for targeted advertising.
Recruitment Data	Affiliates and subsidiaries Business partners Service providers Professional consultants Law enforcement, government agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.
Employment Data	Affiliates and subsidiaries Service providers Professional consultants Law enforcement, government agencies, and other recipients for legal, security, or safety purposes In connection with a corporate transaction Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.
Interview Data	Affiliates and subsidiaries Service providersProfessional consultants Law enforcement, government agencies, and other recipients for legal, security, or safety purposes Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.
Communications Data	Affiliates and subsidiaries Service providersProfessional consultants Law enforcement, government agencies, and other recipients for legal, security, or safety purposes Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.
Visit Data	Affiliates and subsidiaries Service providers Law enforcement, government agencies, and other recipients for legal, security, or safety purposes Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.
Other Data	Affiliates and subsidiaries Service providersLaw enforcement, government agencies, and other recipients for legal, security, or safety purposes Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.
Inferences	Affiliates and subsidiaries Business partners Service providers Professional consultants Law enforcement, government agencies, and other recipients for legal, security, or safety purposes Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.
Sensitive Data	Affiliates and subsidiaries Business partners Service providers Professional consultants Law enforcement, government agencies, and other recipients for legal, security, or safety purposes Entities to which you have consented to the disclosure	We do not sell or share this data for targeted advertising.

Sensitive Data: We only use and disclose Sensitive Data for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device; or (viii) for purposes that do not infer characteristics about you.

Contact Information

If you have questions regarding this Notice, please contact us at: [email protected]