Last Modified: December 31, 2019
1. OUR APPROACH TO PRIVACY
2. HOW WE COLLECT AND USE INFORMATION
2.1 We collect personal information from our Site visitors in order to provide you with a personalized, useful and efficient experience. The categories of information we collect can include:
2.1.1 Information that you provide to us. Information you provide through the Service (including, without limitation, when you set up an account with us) and on applications or other forms, or through discussions we have with you or your representatives, such as your company name, your name and email address as well as information you provide about your company, including expenses, financing and other information you provide.
2.1.3 We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products, services that may be of interest to you or to communicate with you about employment or business opportunities with our portfolio companies. We may also send you Service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Service, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Control Over Your Information” below.
3.1 We, and our third party partners, automatically collect certain types of usage information when you visit our Site, use our Service, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information (collectively, “ device data”). When you access our Site and/or Service from a mobile device, the device data we collect may include unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Site and Service and to understand more about the demographics of our users. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time. We also collect information about the way you use our Site and Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Site and Service, whether you open emails or click the links contained in emails, and other actions you take on the Site and Service (collectively, “ online activity data”).
3.2 We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Site or use the Service; (b) provide custom, personalized content and information, including targeted content and advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our Service.
3.3 If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Site and Service, as some features and services on our Site and/or Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
4.0 HOW WE SHARE PERSONAL INFORMATION
4.1 We may share your personal information in the instances described below. For further information on your choices regarding your information, see “Control Over Your Information.”
4.1.1 We may share your personal information with third-party service providers or business partners who help us deliver or improve our Service or who perform services on our behalf, such as identifying and serving targeted advertisements, processing payments, sending postal mail, providing back-office services, or measuring Service traffic.
4.1.2 We may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties.
4.1.3 We may share or disclose your personal information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our Terms of Service and User Agreement.
5.0 CONTROL OVER YOUR INFORMATION
5.1 Email Communications. From time to time, we may send you emails regarding updates to our Service, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
5.2 Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through “profile,” “account,” “settings,” or “preferences” options provided on the Service. If you have any questions about modifying or updating any information in your account, please contact us at the email or postal address provided below.
6.0 DATA PROTECTION AND SECURITY
6.1 Data Retention. Following termination or deactivation of your user account, Company may retain your information for a commercially reasonable time for recordkeeping, audit or other purposes.
6.2 Keeping Information Safe. Company cares about the security of your information and uses commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
7.0 LINKS TO THIRD PARTY WEBSITES AND SERVICES
8.0 CHILDREN’S PRIVACY
8.1 Company’s Service is intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 16. If we learn that any personal information has been collected inadvertently from a child under 16, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 16, please contact us at firstname.lastname@example.org.
10.0 CONTACT US
Scale Venture Partners
950 Tower Lane, Suite 1150
San Mateo, CA 94404
11.0 INFORMATION FOR CALIFORNIA RESIDENTS
11.1 Scope. This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“ CCPA”), and their rights with respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In addition, this section does not apply to information we collect from you in the course of communicating with you in your capacity as an employee, controlling owner, director, officer or contractor of an organization (i.e., company, partnership, sole proprietorship, non-profit or government agency) in the context of performing due diligence on, or providing or receiving products or services to or from, such organization. In some cases we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.
11.2 Your California privacy rights. As a California resident, you have the following rights as of January 1, 2020:
11.2.1 Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
220.127.116.11 The categories of Personal Information that we have collected.
18.104.22.168 The categories of sources from which we collected Personal Information.
22.214.171.124 The business or commercial purpose for collecting and/or selling Personal Information.
126.96.36.199 The categories of third parties with whom we share Personal Information.
188.8.131.52 Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third party recipient.
184.108.40.206 Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
11.2.2 Access . You can request a copy of the Personal Information that we have collected about you during the past 12 months.
11.2.3 Deletion. You can ask us to delete the Personal Information that we have collected from you.
11.2.4 Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
11.3 How to exercise your rights. You may submit a request to exercise your right to information, access or deletion by emailing email@example.com. We reserve the right to confirm your California residency to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. Government identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases we may decline your request as permitted by law.
11.4 Personal Information that we collect, use and disclose . We collect Personal Information in the following categories specified by the CCPA:
11.4.1 Identifiers, such as your name and contact details.
11.4.2 Professional or employment information, such as your job title, professional affiliations and employment history.
11.4.3 Online identifiers, such as the device data described above in Section 2.
11.4.4 Internet information, such as the online activity data described above in Section 2.
11.4.5 Sensory information in the form of security camera footage taken in our offices.
11.4.5 Inferences derived from any of the foregoing.
11.5 Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described above. We collect this information from you or “other sources” described above in Section 1. We use this information for the business/commercial purposes described above in Sections 1 and 2. We disclose this information to third parties as described in Section 3. Based on our current understanding of the CCPA, we do not “sell” your Personal Information as defined in the CCPA.