Privacy Policy

Effective Date: October 11, 2018

This Privacy Policy (“Policy”) applies to the website located at www.clear.ventures (the “Site”) that is operated by Clear Venture Management LLC (“Company”, “us”, “our”, and “we”). It explains how the Company may collect, use, and disclose information we obtain through the Site. If you use or provide information through the Site, then you agree to the collection and use of information in relation with this Policy. If you do not agree to this Policy, please do not use the Site or provide us personal information.

The Controller of the Site and the personal information collected through the Site is Clear Venture Management LLC, 2209 El Camino Real, Palo Alto, CA 94306.

Please note that persons in the European Union are entitled to certain rights, which are described in the section entitled “Data Subjects in the EU.”

Effective Date and Changes to this Policy

This Policy is current as of the Effective Date set forth above. Please note that we may change this Policy from time to time and will post any such changes to this Policy on the Site. Therefore, it is important to view the Policy periodically.

The Information We Collect About You

We collect information about you directly from you and from third parties, as well as automatically through your use of our Site.

Information We Collect Directly. You may browse certain areas of the Site without registering with us or providing us personal information.

If contact us at the email address below, we will collect your name, email address and other information necessary to respond to your inquiry.
If you register for resources or newsletters through our Site, we will collect your email address and a password you create. We use this information to set up the account through which you can access resources we provide or to send your newsletter. You can opt out of receiving newsletter at any time by clicking the unsubscribe button in the email or contacting us at the email set forth below.
If you attend one of our events, we may collect your [Name, Company, Email]. We use this information for registration and administrative purposes relating to the event.
If you are a limited partner in one of our investments, we will collect certain including [Name, Company, Email] through which you can access your account (provided through Carta.com).

Information We Collect Automatically. We may automatically collect the following information about your use of our Site through cookies and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; your device ID; the length of time you visit our Site; and the referring URL, or the webpage that led you to our Site. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

How We Use the Information We Collect

We use personal information for a variety of purposes including:

To provide our Site and services to you, to communicate with you about your use of our Site, to respond to your inquiries, and for other customer service purposes.
To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using our Site.
For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, or to contact you about companies or investments we think may interest you.
To better understand how users access and use our Site, both on an aggregated and individualized basis, in order to improve our Site and respond to user desires and preferences, and for other research and analytical purposes.

How We Share Your Information

We may share your information, including personal information, as follows:

Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our agreements or this Policy, or as evidence in litigation in which we are involved.
Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties and publicly for marketing, advertising, research or similar purposes.

Except as noted above, we will not share your information with any third party for direct marketing purposes.

Cookies and Other Tracking Mechanisms

We may use cookies in an effort to improve the quality of our Site. A cookie is a small data file that is sent to your computer when you first visit a website. Cookies usually include an identification number that is unique to the computer you are using. Such identifier can help us better understand our users and how they are using the website and the services. Cookies can improve the quality of service e.g. recognizing a user when he visits the site, displaying the site according to the user’s chosen user settings for language, and maintaining the security of the user’s account.

There are two types of cookies: session and persistent cookies.

Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

If you prefer, however, you can reset your browser so that it refuses all cookies, or notifies you when a cookie is being sent. Currently, our systems do not recognize browser “do-not-track” requests. You may disable certain tracking mechanisms as discussed in this section (e.g., by disabling cookies), but such disabling will impair use of the Site.

Data Analytics

We may directly collect analytics data, or use third-party analytics tools, such as Google Analytics to help us measure traffic and usage trends for the Site. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Sites. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user. You have the opportunity to object the processing of data through Google Analytics by installing a Browser-Add-On available at https://tools.google.com/dlpage/gaoptout You may obtain further information with respect to Google Analytics as well as their current Privacy Policy at https://policies.google.com/privacy?hl=en&gl=us.

Data Subjects in the EU

For persons located in the European Economic Area (“EU Data Subjects”), we will process your personal information in accordance with the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (GDPR). If you are located in the European Union, you are entitled to the following rights with regard to your personal information and data:

Right of access to your personal data, to know what information about you we hold
Right to correct any incorrect or incomplete personal data about yourself that we hold
Right to restrict/suspend our processing of your personal data

Additional rights that may apply to you in certain instances:

Right of data portability
Right to withdraw consent at any time (if processing is based on consent)
Right to object to processing (if processing is based on legitimate interests)
Right to object to processing of personal data for direct marketing purposes
Right of erasure of your personal data from our system (“right to be forgotten”) if certain grounds are met

To exercise your privacy rights, you can email us at the address given below in the “How Can I Contact Clear Ventures” section of this Policy.

If you believe our processing of your personal information violates data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged violation.

For EU Data subjects, we rely on the following legal bases to process your personal information:

Performance of a contract: The use of your personal information may be necessary to perform the contract that you have with us (such as an investment contract).
Legitimate interests: We may use your information for our legitimate interests, such as to provide you with the best suitable content of the Site, emails and newsletters, to improve and promote our products and services and the content on our Site, and for administrative, fraud detection and legal purposes.
Consent: We may rely on your consent to use your personal information for certain purposes, including direct marketing purposes (such as email marketing). You may withdraw your consent at any time by contacting us at the addresses at the end of this Policy. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Retention

We apply a general rule of keeping personal information only for as long as required to fulfill the purposes for which it was collected. However, in some circumstances, we may retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. In specific circumstances, we may also retain your personal information for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

Location of Personal Information/Transfers to the United States

We will transfer, store, and process information that we collect about you, as described in this Policy, in the United States, which may not provide the same level of protection for your personal information as your home country. In addition, we may further transfer your information outside the United States for the purposes described in this Policy. By submitting any personal information or by using the Site, and without limitation to any other rights or obligations we have, you consent to such transfer to, and processing in, the United States and these other countries, and acknowledge that your information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.

Third-Party Links

Our Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Security

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, mobile device, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Children’s Privacy

Our Site and services do not address anyone under the age of 18. We do not knowingly collect personal identifiable information from children under 18. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at the email set forth below.

How Can I Contact Clear Ventures?

You may contact us with any questions relating to this Privacy Policy or submit any complaints or concerns by email at [email protected]