Privacy Policy

Top Down Founders Fund I Limited Partnership, Top Down Founders Fund I GP Ltd., Top Down Founders Fund Management Ltd. and affiliated companies (collectively, the “Top Down Group”)Privacy Policy Statement

The Top Down Group ("TDG") is committed to preserving the privacy of all non-public personal information or personal data ("Personal Data") it receives and maintains. This policy describes what Personal Data TDG collects and processes, how it is used and what measures are taken to safeguard the confidentiality of this information.

Whose Personal Data Does TDG Process?TDG may process your Personal Data if you fall under one of the following categories of individuals ("Data Subjects"):

Website visitors and users. You are visiting and/or using TDG's website

Investors and connected persons of investors. You are an investor (partner, member or shareholder) in TDG (“Investor”) you are connected with an Investor in any of the following ways:

• You control a legal entity Investor through ownership or vested executive powers or authority,
• You are employed by or act as an agent or representative, either directly or indirectly, of an Investor,
• You are employed by or act as an agent or representative, either directly or indirectly, of a service provider of an Investor and TDG interacts with you at the Investor's instruction, or
• You are not in one of the above categories, but you interact with TDG in connection with an Investor's investment in TDG.

If you are a visitor or user of our website, please visit  for an explanation on how your Personal Data is obtained.

If you are an Investor or a connected person of an Investor, you may have provided your Personal Data to us. We may also have collected Personal Data from publicly accessible sources for anti-money laundering, background checking or similar purposes, or directly from a third party (e.g., sanctions screening providers or customer due diligence providers), to protect our business and to comply with our legal and regulatory obligations.

Why Does TDG Process Personal Data?

The following are the purposes and lawful grounds for TDG's processing of Personal Data.

Performance of Contractual Obligations - Business Purpose. If you are an Investor, you have entered into an agreement with TDG. Your Personal Data is processed in connection with TDG's performance of its obligations under the agreement. The processing is performed for a business purpose and is done by TDG as part of the services that TDG provides to you and in accordance with the terms of your agreement with TDG.

Compliance with Legal Requirements. TDG is subject to the regulation and oversight of regulatory authorities in various jurisdictions and may be required to process Personal Data to comply with Canadian (federal and provincial), US (federal and state) and other jurisdictions’ securities laws, tax laws, anti-money laundering laws and regulations, international treaties and agreements.

Consent. TDG may be processing Personal Data because you consented to such processing either by using TDG's website or by signing an agreement with TDG. Personal Data processed pursuant to your consent may be used in connection with the operation of TDG's website or to fulfil the purpose for which the Personal Data was provided to us, such as to respond to your inquiry about the services or to perform and manage the services we provide.

What Personal Data Do We Process?

The information we process in connection with the use of our website is described at 

Personal Data that TDG processes in connection with the performance of services to Investors includes:

Contact Information. This may include mailing and postal address, email address, and a phone number.

Identification Information. Information and documentation maintained to comply with anti-money laundering, tax reporting and similar laws and regulations.

Other Information Necessary to Perform Services. TDG may have to maintain other records such as banking information and transaction history.

Who are the Recipients of your Personal Data? Where your Personal Data May Be Transferred?

Please refer to  for the information regarding our disclosure of the Personal Data of the visitors and users of our website.

The Personal Data of Investors or connected persons of an Investor is considered confidential information under the agreements between TDG and its Investors. TDG may transfer such Personal Data to third parties where authorized under the agreement between TDG and the investor. Authorized transfers under the agreement may include transfers necessary in connection with the performance of the services, such as to other service providers of TDG, or transfers which are legally required, such as transfers to regulators. TDG may also transfer your Personal Data upon written instructions of an Investor. Some of the third party transferees may be based outside the European Economic Area (EEA) or the United Kingdom (UK). For more information, including on how we safeguard your Personal Data when this occurs, see below: "Transferring Your Personal Information Out of the EEA/UK".

TDG has not sold to a third party any personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Transferring Your Personal Data Out of the EEA/UK

To deliver services to our Investors, it is necessary for TDG to share Personal Data outside of the EEA and the UK. Non-EEA/UK countries do not have the same data protection laws as the EEA or the UK. In such cases, TDG will ensure that its arrangement with the recipient is governed by data transfer agreements designed to ensure that Personal Data is protected on terms approved for this purpose by the European Commission.

How Does TDG Assure Security of Personal Data?

TDG is committed to protecting the security and integrity of Personal Data. In pursuit of our commitment, we have in place commercially reasonable safeguards and controls to ensure that any Personal Data collected is protected against unauthorized access, disclosure, alteration and destruction. TDG has adopted, implemented and adheres to an Information Security and Risk Management Policy ("ISRM Policy"). TDG's ISRM Policy: defines which employees have access to the Personal Data; describes the safeguards and controls used to protect Personal Data; and describes the administrative, electronic and technical security measures in place.

How Long Does TDG Maintain Your Personal Data?

TDG may retain your Personal Data indefinitely for record keeping and pursuant to routine system backup processes. TDG may be required under various laws and regulations to maintain certain Personal Data for a mandated period.

How to Contact the Person Responsible for Proper Processing of Your Personal Data?

If you are an Investor or a connected person of an Investor, TDG is responsible for the proper handling of your Personal Data is TDG. Please review respective TDG offering documents for the contact information relating to relevant inquiries.

Alternatively, you can send your inquiry to us at info@topdown.com, and we will link you with the appropriate party at TDG. If you choose to contact TDG directly, you may need to provide us with additional information as necessary to authenticate your identify for your data security. Please note: we are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person's behalf.

If you are not an Investor or a connected person of an Investor, but you are a visitor to our website, please refer to our  for the relevant contact information.

Residents of the European Union or the United Kingdom

The below notice relates specifically to the processing by TDG of Personal Data of natural persons who reside in the European Union or the United Kingdom and provides additional information required under both the EU General Data Protection Regulation 2016/679 ("EU GDPR") and the Retained Regulation (EU) 2016/679 (individually the "UK GDPR" and collectively with the EU GDPR, the "GDPR").

What Are the EU/UK Data Subject's Rights with Respect to Personal Data?

Right to Be Informed. Data Subjects have the right to be informed about Personal Data we collect and how this data is used.

Right to Access and Portability. Data Subjects have the right to obtain a confirmation whether we are processing their Personal Data and to obtain copies of their Personal Data or to request that we forward such copies to another person.

Right to Rectification. Data Subjects have the right to make a request to correct any inaccuracy or incompleteness of their Personal Data.

Right to Erasure. Data Subjects have the right to make a request to delete their Personal Data.

Right to Restrict Processing. Data Subjects have the right to ask us to restrict the processing of their Personal Data for a period when the accuracy of the data is verified, or if they think that the processing is unwarranted.

Right to Object. Data Subjects have a right to object to processing of their Personal Data in certain circumstances, such as, when the data is used for marketing.

Right to Withdraw Consent. If a Data Subject has given consent to the processing of Personal Data, Data Subject has the right to withdraw the consent at any time.

Right to Lodge a Complaint. Data Subjects have a right to lodge a complaint with a supervisory authority if they consider that the processing of Personal Data infringes GDPR. For residents of the UK, the appropriate supervisory authority is the Information Commissioner's Office. For residents of the EU, the appropriate contact is the supervisory authority in the EU state of their residence, place of work or place of the alleged infringement.

The rights enumerated above are subject to certain conditions and exemptions. Where such conditions or exemptions apply, we have a right not to comply with the request. Additionally, while in most circumstances requests based on the above listed rights shall be fulfilled free of charge, TDG is allowed and may charge fees to fulfill the request.

How to Contact the Person Responsible for Proper Processing of Your Personal Data?

If you are an Investor or a connected person of an Investor, TDG is the person who is responsible for the proper handling of your Personal Data, known as the data controller. Please review respective TDF offering documents for the contact information relating to GDPR inquiries.

Alternatively, you can send your inquiry to us at info@topdown.com and we will link you with the appropriate party at TDG. If you choose to contact TDG directly, you may need to provide us with additional information as necessary to authenticate your identify for your data security. Please note: we are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person's behalf.

If you are not an Investor or a connected person of an Investor, but you are a visitor to our website, please refer to our  for the relevant contact information.

Residents of California

This notice specifically relates to the collecting by TDG of Personal Data of individuals who reside in California and provides additional information relevant under the California Consumer Privacy Act of 2018 (Cal. Civ. Code 1798.100 et seq) ("CCPA").

What Rights Are Granted to California Data Subjects?

Right to Access and Portability. Data Subjects have the right to request the information about the categories of Personal Data being collected and the purposes for which the Personal Data is being collected, as well as the categories of the sources from which the Personal Data is collected, the categories of third parties with whom the business shares Personal Data, and the specific pieces of Personal Data that were collected. Data Subjects have the right to obtain copies of their Personal Data in a readily useable format that allows the consumer to transmit this information from one entity to another entity without hindrance.

Right to be Forgotten. Data Subjects have a right to make a request to delete Personal Data.

Non-Discrimination. TDG may not discriminate against a Data Subject because the Data Subject exercises any of the rights under the CCPA. TDG will not deny Data Subjects services, charge different prices or rates for services, or provide a different level or quality of service in retaliation for exercising CCPA rights.

Right to Opt Out. Data Subjects have the right to request that a business that sells Personal Data about the Data Subject to third parties not sell the Data Subject's Personal Data.

The rights enumerated above are subject to certain conditions and exemptions. Where such conditions or exemptions apply, we have a right not to comply with the request. Additionally, while in most circumstances requests based on the above listed rights shall be fulfilled free of charge, TDG is allowed and may charge reasonable fees to fulfill the request.

TDG has a policy not to sell any Personal Data and it has not sold any Personal Data in the last 12 months.

TDG may transfer such Personal Data, including identification, commercial and geopolitical information, to third parties, where authorized by you under your agreement with TDG. In the last 12 months, the authorized transfers under the agreement included transfers to TDG affiliated entities in the course of performance of the services, to other service providers of TDG as necessary in connection with the performance of the services, and transfers which are legally required, such as transfers to regulatory or governmental entities. TDG may also transfer your Personal Data upon your written instructions.

Privacy Policy www.topdown.com/privacy-policy