TIGERROCK

Privacy Notice

Regulators, including the U.S. Securities and Exchange Commission, have regulations emphasizing the obligations of financial institutions to protect the privacy of nonpublic personal information of individuals. Tiger Global Management, LLC takes our clients' and investors' privacy seriously. Please read this notice carefully to understand how we collect, share, and protect your personal information.

We do not disclose nonpublic personal information about past, current, or prospective clients or investors without their prior authorization to third parties other than as described below.

Personal Information We Collect

We collect personal information about you in connection with our providing advisory services to you. This information includes your social security number and may include other information such as your:

  • Assets
  • Investment experience
  • Transaction history
  • Income
  • Bank account information
  • Wire transfer instructions

How We Collect This Information

We collect this information from you through various means. For example, when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other non-affiliated companies.

How We Use This Information

All financial companies need to share customers' personal information to run their everyday business and we use the personal information we collect from you for our everyday business purposes. These purposes may include for example:

  • To provide advisory services to you
  • To open an account for you
  • To process a transaction for your account
  • To market products and services to you
  • To respond to court orders, regulatory requests, and legal investigations

Disclosure to Others

We may provide your personal information to our affiliates and to firms that assist us in servicing your account and have a need for such information, such as a broker or fund administrator. We may also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements. We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them.

How We Protect Your Personal Information

To protect your personal information from unauthorized access and use, we use security measures that comply with Federal law. These measures include computer safeguards and secured files and buildings.

Cayman Islands, EU and UK Privacy Notice

The Cayman Islands Data Protection Law, 2017, the European Union's General Data Protection Regulation and the UK GDPR govern the use of personal data by Cayman Islands investment funds managed by Tiger Global. Tiger Global recognizes the importance of protecting the privacy of investors in its funds and asks that you please read this Privacy Notice carefully to understand how we collect, share, and protect the personal information of investors in our Cayman Islands funds.

Personal Information We Collect and How It Is Collected

We, our service providers and Tiger Global affiliates may process the following types of personal data in connection with our providing advisory services to you:

  • Personal data provided by you: including your name, address, contact information, birthdate, gender, nationality, photograph, signature, occupational history, job title, income, assets, other financial information, bank and brokerage details, investment experience, tax residency, and tax identification information
  • Personal data collected or generated by us: including information related to emails, correspondence, call recordings, and website usage data
  • Personal data obtained from other sources: including Know Your Client procedures, anti-money laundering, counter-terrorist financing, sanctions, FATCA, CRS, information from public websites, and information received from your advisors or intermediaries

Legal Basis for Processing

We process your personal data based on:

  • Performance of a contract: including investor assessment procedures, managing and administering your holdings, distribution payments, and periodic reporting
  • Compliance with legal obligations: including AML/CTF regulations, FATCA/CRS reporting, and other regulatory requirements
  • Legitimate interests: including ordinary business activities, compliance with legal obligations, fraud prevention, and record keeping

Personal Data Recipients

We may disclose your personal data to:

  • Affiliates and third party service providers engaged in investment management and administration
  • Professional advisors, bankers, brokers, auditors, IT, and other service providers
  • Competent authorities, regulators, courts, and law enforcement agencies as required by law

International Transfers

Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection of personal data. Where such transfers occur, we will take steps to ensure the security and confidentiality of your personal data in accordance with applicable data protection laws.

Data Subject Rights

You have a number of legal rights in relation to the personal data that we hold about you, including:

  • The right to obtain information regarding the processing of your personal data and access to that data
  • The right to receive certain personal data and request transmission to a third party
  • The right to request rectification if your personal data is inaccurate or incomplete
  • The right to request erasure of your personal data in certain circumstances
  • The right to object to and restrict processing in certain circumstances
  • The right to lodge a complaint with the data protection regulator

Contact Information

If you have any questions regarding this Privacy Notice, please contact us at ir@tigerglobal.com or call us at 212-984-8800.

For further information regarding your personal data rights, you can visit the UK's Information Commissioner's Office at ico.org.uk or the Ombudsman's website at www.ombudsman.ky.