SCALE VENTURE PARTNERS INTERNATIONAL PRIVACY POLICY


LAST MODIFIED: JUNE 15, 2018

1. OUR APPROACH TO PRIVACY

1.1 Scale Management, L.L.C. ("ScaleVP", "we", "our", or "us") is committed to protecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.

1.2 ScaleVP operates a platform that allows users to submit information about their companies, and to view trends and other benchmarking data calculated based on that information, which it makes available through its website (the "ScaleVP Service").

1.3 This privacy policy applies to the ScaleVP Service.

1.4 Before accessing or using the ScaleVP Service, please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this privacy policy.

2. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

2.1 We collect personal information about you when you voluntarily submit information directly to us when you create an account on the ScaleVP Service, as well as when you access or use the ScaleVP Service. This can include information you provide to us when you register for an account, fill in a form or submit any information to us through the ScaleVP Service, when you communicate with us by phone, email or otherwise, when you subscribe to our blog, mailing lists, newsletters or other forms of marketing communications, or when you use some other feature of the ScaleVP Service as available from time to time.

2.2 If you choose not to provide personal information, we may not be able to provide the ScaleVP Service to you or respond to your other requests.

2.3 The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.

2.4 We also automatically collect personal information about you indirectly about how you access and use the ScaleVP Service and information about the device you use to access the ScaleVP Service.

2.5 The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information, the categories of recipients of the personal information and information as to how we determine applicable retention periods.

2.6 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

2.7 We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the ScaleVP Service and developing new products and features. We may also share such anonymised information with others.

3. MARKETING AND ADVERTISING

3.1 From time to time we may contact you with relevant information about the ScaleVP Service. Most messages we send will be by email. For some messages, we may use personal information we collect about you to help us determine the most relevant information to share with you.

3.2 If you do not want to receive such messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can change your marketing preferences by clicking on the unsubscribe link at the bottom of our emails.

4. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

 

4.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on secure servers. All electronic transactions entered into via the ScaleVP Service will be protected by SSL encryption technology.

Where you register for an account on the ScaleVP Service you are responsible for maintaining your account’s security as more specifically explained in the Terms of Use.

4.2 International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the European Economic Area ("EEA"), your personal information will be processed outside of the EEA including in the United States.

5. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

5.1 This section applies to you if you are located in the EU.

5.2 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a) Right of access. The right to obtain access to your personal information.

(b) Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.

(c) Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.

(d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.

5.3 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

5.4 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

6. COOKIES AND SIMILAR TECHNOLOGIES

6.1 Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.

6.2 Cookies are pieces of code that allow for personalisation of our website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device's hard disk (such as your computer or smartphone) for record-keeping purposes.

6.3 We use the following types of cookies:

(a) Strictly necessary cookies. These are cookies that are required for the essential operation of our website such as to authenticate users and prevent fraudulent use.

(b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.


(c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).


Please be aware that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

6.4 The cookies we use are designed to help you get the most from the website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

(a) Cookie settings in Internet Explorer

(b) Cookie settings in Firefox

(c) Cookie settings in Chrome

(d) Cookie settings in Safari web and iOS.

7. LINKS TO THIRD PARTY SITES

The ScaleVP Service may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

8. OUR POLICY TOWARDS CHILDREN

8.1 The ScaleVP Service is not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

9. CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

10. NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

11. CONTACTING US

11.1 Questions, comments and requests regarding this privacy policy are welcome and should be addressed to scale-privacy@scalevp.com.

11.2 This privacy policy was last modified on June 1, 2018.

ANNEX 1 – PERSONAL INFORMATION WE COLLECT WHEN YOU USE THE SCALEVP SERVICE

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY