CRUCIBLE VENTURES WEBSITE PRIVACY POLICY
Last modified: March 28, 2020
Our Commitment to Your Privacy
This Privacy Policy applies to www.crucibleventures.com (the “Site”), which provides information about the affiliated entities commonly referred to as “CVP”. This privacy policy only applies to information we may collect from visitors to the Site or that visitors to the Site may provide through the Site.
If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.
Information We Collect
This Site does not directly collect any personal information. You may, however, chose to contact us by email, in which case we will collect your name, email address and any other information that you chose to provide to us. Please do not provide personal information that you do not want us to have.
In addition, we may gather information about you automatically through your use of the Site, e.g., your IP address and how you navigate our Site. CVP may collect information about you by using cookies, tracking pixels and other technologies (collectively, “Tools”). We may use this information to better understand, customize and improve the user experience of our websites, services and offerings. For example, we may use web analytics services such as Google Analytics that leverage Tools to help us understand how visitors engage with and navigate our Site. Information on how Google Analytics collects and processes your data is available here: www.google.com/policies/privacy/partners/. We may also use performance tracking cookies to enhance the performance of our website.
Your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to you. If your browser is set to reject cookies, the Site may not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, including how to see what cookies have been set and how to manage or delete them, visit www.allaboutcookies.org.
How We Use the Information We Collect
If you choose to provide information to us, for example by email, the information is used for the purpose you provided it to us. For example, if you provide your contact information in an inquiry to us, we will use your contact information to process and respond to that inquiry and any related activity that may result from your inquiry.
How We Share the Information We Collect
We may share your personal information Crucible Venture Partners, LLC and its affiliates for the purposes described in this Policy. We may share personal information with service providers that perform services on our behalf such as payment service providers, analytics providers, and hosting providers. In accordance with applicable law, we have entered into legally binding agreements requiring them to use or disclose personal information only as necessary to perform services on our behalf or comply with applicable legal requirements.
In addition, we may disclose personal information about you (a) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
Links to Third-Party Websites
The Site may contain links to other web sites. We have no control over and are not responsible for the privacy policies or practices of such sites. Whenever you link to another web site, you may be asked to provide registration or other information. Please note that any information that you provide is going to a third party, and therefore you should familiarize yourself with that party’s privacy policy.
Data Transfers
The Site is controlled and operated from the United States and is not intended to be subject to the laws or jurisdiction of any country or territory other than that of the United States.
Information Security
We maintain appropriate technical and organizational measures designed to protect your personal information against loss or accidental, unlawful or unauthorized, alteration, access, disclosure or use. Unfortunately, no data transmission or storage system can be guaranteed 100% secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately.
Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they don’t track the user. CVP does not change its practices, described elsewhere in this privacy policy, in response to Do Not Track browser settings or signals. For information about DNT, visit www.allaboutdnt.org.
Third parties may collect personal information about your online activities over time and across different websites, including your use of this Site. This Privacy Policy does not apply to, and we are not responsible for, the practices of third parties that collect your personal information.
How Long We Keep Information
The time period for which we keep personal information depends on the purposes for which we collected it. In all cases we keep it for as long as necessary to fulfill those purposes. We will then delete this personal information unless we are required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required or permitted by applicable law.
Governing Law
This Privacy Policy forms part of our Terms of Use and as such shall be governed by and construed in accordance with the laws of the state of California, as further provided in the Terms of Use.
Information for EU Residents
Crucible Venture Partners, LLC is the data controller in respect of personal information collected through the Site.
We process your personal information for the purposes described above on the basis that it is necessary for our legitimate interests in operating, managing and improving the Site. We may use your personal information to send direct marketing only where you have provided your consent or otherwise when we are permitted by applicable law to do so.
If you are located in the European Economic Area (“EEA”), we comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA and Switzerland. In all such cases, we will only transfer your personal information if:
The country to which the personal information will be transferred has been granted a European Commission adequacy decision;
The recipient of the personal information is located in the U.S. and has certified to the US-EU Privacy Shield Framework; or
We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.
You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in the How to Contact Us section below.
If you are located in the EEA or Switzerland, subject to applicable law, you may have the following rights in relation to personal information that we hold about you:
To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal information;
Where you have given us consent to process your personal information, to withdraw your consent; and
To request that we provide a copy of your personal information to you in a structured, commonly used and machine readable format in certain circumstances.
To object to certain of our data processing, such as for direct marketing purposes.
If you are located in the EEA and you wish to exercise any of your data protection rights or if you consider that we have processed your personal information in violation of applicable law, please contact us as detailed in the “How to Contact Us About Privacy Matters” section below.
If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.
How to Contact Us About Privacy Matters
If you would like to contact us for any reason concerning our privacy practices, please email us at privacy@crucibleventurepartners.com.
Updates to this Privacy Policy
We may change or update portions of this Privacy Policy at any time without notice to you. Please check back from time to time so you are aware of any changes or updates to the Privacy Policy. The revision date appearing on the first page of this Privacy Policy underneath the title will identify the date of the last update or revision.
Exceptions to this Privacy Policy
This privacy policy applies only to the public sections of the Site. If you are permitted access to private areas, the terms of your subscription agreement will control our use of provided information.
CALIFORNIA CONSUMER PRIVACY STATEMENT
Effective: January 1, 2020
This Statement does not apply to (i) CVP personnel or job applicants seeking opportunities at CVP, (ii) personnel working on behalf of business partners with whom we are conducting business, or (iii) information collected, processed, sold or disclosed pursuant to the Gramm-Leach-Bliley Act (and its implementing regulations) or the California Financial Information Privacy Act.
This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
1. Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you online or offline:
Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags; unique pseudonym or user alias; telephone number), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, disability, citizenship status, and military and veteran status
Commercial Information: commercial or investment information, including records of personal property, financial products or investment services purchased, obtained, or considered, and other investing or consuming histories or tendencies
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Sensory Information: audio, electronic, visual, and similar information
Employment Information: professional or employment-related information
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use the categories of personal information listed above for the purposes described in the CVP Website Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described below:
Purpose: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Employment Information; and Inferences
Purpose: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, auditing compliance
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences
Purpose: Short-term, transient use
o Categories of Personal Information: Identifiers; Online Activity; and Inferences
Purpose: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Commercial Information; Online Activity; Sensory Information; and Inferences
Purpose: Debugging to identify and repair errors that impair existing intended functionality
o Categories of Personal Information: Identifiers; Online Activity; and Inferences
Purpose: Undertaking internal research for technological development and demonstration
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences
Purpose: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences
2. Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.
a. Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.
Categories of Sources of Data Collection: From you, for example, through your use of our websites, when you send us an email, visit our facilities, or otherwise contact or communicate with us
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Online Activity; Sensory Information; Employment Information; Education Information and Inferences
Categories of Sources of Data Collection: From monitoring tools, such as cookies that Identifiers; Additional Data Subject to Cal. Civ. track your use of our websites and security cameras in certain of our facilities;
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Online Activity; Sensory Information and Inferences
Categories of Sources of Data Collection: Our affiliates
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Employment Information; Education Information and Inferences
Categories of Sources of Data Collection: Our portfolio companies
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Employment Information; Education Information and Inferences
Categories of Sources of Data Collection: Businesses that we are evaluating in connection with a potential investment or business opportunity
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Employment Information; Education Information and Inferences
Categories of Sources of Data Collection: Vendors (e.g., background check providers), advisors and other business partners
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Employment Information; Education Information and Inferences
Categories of Sources of Data Collection: Recruiting agencies, social media networks or publicly available sources
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Employment Information; Education Information and Inferences
b. Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below.
Categories or Third Parties: Our affiliates
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; Education Information and Inferences
Categories or Third Parties: Vendors, broker-dealers, advisors and others who provide services to us or on our behalf
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Sensory Information; Employment Information; Education Information and Inferences
Categories or Third Parties: Professional services organizations, such as auditors and law firms
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Sensory Information; Employment Information; Education Information and Inferences
Categories or Third Parties: Prospective lenders to or creditors of a fund or portfolio company in which we have or are considering investing
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Employment Information; Education Information and Inferences
Categories or Third Parties: Our portfolio companies
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Employment Information; Education Information and Inferences
Categories or Third Parties: Government entities, including regulatory agencies and law enforcement
o Categories of Personal Information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; Sensory Information; Employment Information; and Inferences
We have not sold personal information during the 12-month period prior to the effective date of this California Consumer Privacy Statement.
c. Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties for a business purpose all of the categories of personal information about you listed in Section 1 above.
3. California Consumer Privacy Rights
You have certain choices regarding our use and disclosure of your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
How to Submit a Request: To submit an access or deletion request, email us at privacy@crucibleventurepartners.com
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request access to or deletion of your personal information, we may require you to provide any of the following information: address, date of birth, unique personal identifier, nationality, telephone number, email address, CV information or details of a transaction. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access or deletion request on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).
Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact privacy@crucibleventurepartners.com to request this Statement in an alternative format.