Privacy Policy
Last Updated: March 1, 2024
This Privacy Policy (“Privacy Policy” or “Policy”) describes how VegaLeap Capital Management, LLC (together with its affiliates, “VegaLeap,” “we,” “us” or “our”) collect, use, retain and disclose personal information from users who use, access or otherwise interact with the www.vegaleap.com website (together with the website’s content and subpages, the “Site”). This Policy only applies to information collected through the Site and does not extend to data gathered by VegaLeap through alternative means, such as via telephone, postal mail or live or print media, unless such information is merged with the data collected through the Site.
BY ACCESSING OR USING THE SITE, YOU HEREBY ACCEPT AND CONSENT TO THIS PRIVACY POLICY IN ITS ENTIRETY. It is advised that you periodically review the Policy as it may be amended from time to time. Notification of any amendments will be communicated exclusively through the updating of the date at the top of this Policy. Your continued access to or use of the Site after any amendments to the Policy have been made will be deemed to be your acceptance of the revised Policy.
We reserve all rights granted to us under applicable law that are not expressly stated herein.
COLLECTION OF INFORMATION
The specific categories of personal information we collect depend on how you interact with and use the Site. Further details are provided below, along with the sources from which we obtain personal information.
Information Provided Directly to Us
We collect personal information directly from you when you visit our Site, submit forms and/or documents or contact us. This may include gathering contact information such as your name, address, email address and phone number and/or employment-related information such as your job title and your employer’s name, address and telephone number.
Information Collected Automatically
We may automatically collect personal information when you access the Site, including device information (e.g., browser type, hardware model, operating system version, IP address and unique device identifiers) and usage data (e.g., dates and times of Site visits, visit duration, frequency of access and interactions with Site hyperlinks). We may use cookies, web beacons and other tracking technologies to collect this information. Cookies are small data files stored on your device to remember your site visits and preferences, whereas web beacons are small graphics used for observing your activity and collecting data on web and email interactions.
VegaLeap may engage third-party analytics providers, such as Google Analytics, to enhance the Site’s functionality. These providers might use cookies, web beacons or similar technologies, which could result in the sharing of personal information that VegaLeap has previously collected. The handling of this information by these third parties, including its use, retention, disclosure and any other processing activities, will be governed by their respective privacy policies.
Deletion of Cookies; Adjusting your Tracking Preferences
You can modify your web browser settings to delete or refuse cookies by consulting the "Help" section of your browser. Please note that disabling cookies may: (i) impact your ability to save your viewing preferences; (ii) affect the display and/or functionality of some or all parts of our site; and (iii) not necessarily stop all forms of tracking. Also, we may not respond to “Do Not Track” requests that are sent to us.
Information Collected from Other Sources
VegaLeap may collect personal and other types of information about you from other sources and merge it with data already gathered through the Site. This collection can encompass professional or employment-related details from external sources such as LinkedIn, as well as due diligence data from our service providers, co-investment entities or other business affiliates. Additionally, VegaLeap reserves the right to obtain any information about you from any external source at any time, to the extent permitted by law.
USE OF INFORMATION
We may use personal information collected about you to: (i) operate, maintain or improve our Site or its services; (ii) respond to your inquiries; (iii) distribute informational content, notices or other communications via the Site, through third-party platforms, by email or through other means; (iv) evaluate job applicants; (v) facilitate our auditing, legal or compliance functions; (vi) deliver our products and services and conduct analyses to refine our offerings; or (vii) create and administer online accounts. VegaLeap may also use your personal information for any other legitimate business reason to the extent permitted by law.
DISCLOSURE OF INFORMATION
We may share the personal information we collect about you with our officers, directors, owners, principals, advisers, agents, employees and third-party service providers in order to: (i) support our technical, professional, legal, tax or accounting functions; (ii) comply with legal or regulatory obligations, including responding to requests from supervisory, regulatory or governmental authorities; or (iii) facilitate a merger, financing, acquisition, dissolution transaction, bankruptcy or proceeding involving a sale, transfer, divestiture of all or a portion of our business or assets. Should our business or certain assets be acquired, the acquiring entity will assume responsibility for the personal information collected, in accordance with this Policy.
PROTECTION OF INFORMATION
Data Retention
We may retain your personal information for the duration necessary to fulfill our professional, regulatory or legal obligations, maintain internal records or satisfy any other commitments specified herein. All personal information collected by us is stored within the United States and is subject United States law. Be advised that these laws may vary significantly from those in your jurisdiction. If you reside outside the United States, you expressly consent to the transfer of any personal information collected about you to the United States.
Data Security
We implement reasonable administrative, technical, personnel and physical security measures to safeguard our network, systems, and Site. These measures are designed to protect the personal information we collect from loss, theft and unauthorized access, disclosure and alteration. However, due to the inherent vulnerabilities of the internet’s global and open structure, we cannot guarantee the absolute security of any personal information transmitted through our Site or stored by us.
PRIVACY POLICIES OF LINKED SITES
Our Site and any correspondence from us may include links to third-party websites. Third-party websites have their own privacy policies and data management practices that govern how they collect, use, retain and disclose information. Upon visiting these websites, be advised that the handling of any personal information they collect about you is governed by their privacy policies, not ours. We bear no responsibility for the data handling practices of these autonomous sites.
CHILDREN’S PRIVACY
This Site is not intended for any individual under the age of 13 (“Child Under 13”). We do not target, direct this Site to or knowingly collect any personal information from any Child Under 13. If we become aware that personally identifiable information about a Child Under 13 has been submitted to the Site, then we will make reasonable effort to promptly delete such information from our records.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: March 1, 2024
This privacy notice (“California Notice”) applies exclusively to Site users who reside in California.
If you are a California resident, then the California Privacy Rights Act (“CPRA”) requires us to inform you about our practices regarding the collection, use and disclosure of your Personal Information (“Personal Information,” as defined below). This California Notice supplements the Privacy Policy. If you are an employee or job applicant residing in California, please refer to our California Employee Privacy Notice.
Collection of Personal Information
The California Consumer Privacy Act of 2018, as amended (“CCPA”), defines “Personal Information” as information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). The table below provides an overview of different categories of Personal Information and indicates whether we have collected data corresponding to these categories from Site visitors within the last 12 months.
| Category of Personal Information (as Defined by the CCPA) | Examples | Collected by VegaLeap (Yes/No) |
|---|---|---|
| Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | Yes |
| Categories of Personal Information Described in Cal. Civ. Code § 1798.80(e) | Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information or health insurance information. | Yes (For prospective employees, consultants, and contractors) |
| Characteristics of Protected Classifications under California or Federal Law | Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information). | No |
| Commercial Information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes (Records regarding investment services and transactions) |
| Biometric Information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No |
| Internet or Other Similar Network Activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | Yes |
| Geolocation Data | Physical location or movements. | Yes (To the extent derived from IP Addresses) |
| Sensory Data | Audio, electronic, visual, thermal, olfactory, or similar information | No |
| Professional or Employment-Related Information | Current or past job history or performance evaluations. | Yes |
| Non-Public Education Information (per the Family Educational Rights and Privacy Act) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | Yes |
| Inferences Drawn from Other Personal Information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes |
Collection of Sensitive Personal Information
Unless you voluntarily provide it to us in a free text format, we do not knowingly collect “Sensitive Personal Information”, as defined and/or considered under the CCPA/CPRA, via the Site.
Business or Commercial Purposes for Collecting Personal Information
We use your Personal Information for purposes specified under the “USE OF INFORMATION” section of the Privacy Policy.
Sources, Sharing, Selling and Disclosure of Personal Information
Your Personal Information is collected from sources specified under the “COLLECTION OF INFORMATION” section of the Privacy Policy.
VegaLeap does not “sell” or “share” Personal Information as those terms are defined and/or considered under the CCPA/CRPA.
We disclose your Personal Information with others as specified under the “DISCLOSURE OF INFORMATION” section of the Privacy Policy.
YOUR RIGHTS UNDER THE CCPA/CRPA
California residents are provided with certain rights under the CCPA/CRPA, including the right to request: (i) a copy of the specific pieces of information collected from you and to receive this Personal Information in a readily usable format; (ii) information pertaining to the categories of Personal Information collected; (iii) the sources from which your Personal Information was collected; (iv) information pertaining to the categories of third parties with whom your Personal Information has been shared; (v) the business or commercial purposes for collecting, disclosing or selling your Personal information; (vi) the correction of inaccurate Personal Information stored in our records; (vii) the erasure of your Personal Information from our records, subject to certain exceptions (Refer to “EXERCISING YOUR RIGHTS” below for more details); (viii) the cessation of the sale or sharing of your personal information with third parties (given that we do not engage in the sale or sharing of personal information for any user of the Site, you are automatically deemed to be opted-out); (ix) that we only use or disclose sensitive personal information collected about you for purposes specified under the CPPA/CRPA. You also have the right to not be discriminated against in the event you exercise, in good faith, any of the rights conferred to you by the CPPA/CRPA.
For instructions on how to exercise any of your rights mentioned above, please refer to the “EXERCISING YOUR RIGHTS” section below.
PRIVACY NOTICE FOR EEA AND UK RESIDENTS
Effective Date: March 1, 2024
This privacy notice (“EEA/UK Data Notice”) applies exclusively to Site users who reside in the European Economic Area (“EEA”) or the United Kingdom (“UK”).
If you currently reside within the EEA or the UK, then the collection, use, retention and disclosure of any personal information we obtain from you through the Site is governed by the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable legislation (collectively referred to as the “Data Protection Laws”). This EEA/UK Data Notice explains our practices regarding the handling and processing of your personal data and specifies the data rights conferred to you under the Data Protection Laws (subject to applicable restrictions).
Under the Data Protection Laws, our role is that of the Data Controller (“Data Controller”), and you, the individual from whom we collect personal information (“Data”), are identified as the Data Subject (“Data Subject”). As the Data Controller, we bear responsibility for the handling and processing of your Data.
The Collection, Use, Retention, Disclosure and Protection of Data
We collect, use, retain, disclose and protect Data collected from Data Subjects via the Site as specified under the “COLLECTION OF INFORMATION,” “USE OF INFORMATION,” “DISCLOSURE OF INFORMATION” and “PROTECTION OF INFORMATION” sections of the Privacy Policy.
Legal Basis for Processing Data
We are legally authorized to process your Data either because you have provided your consent for the processing or because the processing is necessary for: (i) the performance of a contract to which you are a party or for the undertaking of pre-contractual measures at your request; (ii) us to comply with legal obligations; (iii) protecting your vital interests; (iv) for the performance of a task carried out in the public interest; or (v) the purposes of legitimate interests pursued by the us or a third party, subject to certain limitations.
Data Subject Rights
As a Data Subject, you have the right to request: (i) information about how we collect, use and retain your Data; (ii) confirmation of whether your Data is being processed by us; (iii) access to Data retained by us; (iv) the rectification of inaccurate Data stored in our records; (v) the erasure of your Data, subject to certain exceptions; (vi) the restriction of your Data processing, allowing for its storage while forbidding any further processing; or (vii) a copy your Data in a structured, commonly used and machine-readable format and to have such Data transmitted to another Data Controller without hindrance from us. You also have the right to withdraw your consent to the processing of your Data at any time or lodge a complaint with your local data protection authority regarding the processing of your Data.
You may object to the processing of your Data at any time if such objection is: based on your desire to cease receipt of direct marketing; required for the performance of a task carried out in the public interest; or grounded in other legitimate interests, subject to limitations.
For instructions on how to exercise the rights mentioned above, please refer to the “EXERCISING YOUR RIGHTS” section below.
EXERCISING YOUR RIGHTS
If you wish to exercise any of your rights mentioned above, send us your request via email to: privacy@vegaleap.com
Additional Information Regarding Your Request
Verification of Requests
Your request to exercise any of your rights mentioned herein must be made by you or a person authorized to act on your behalf. VegaLeap will take reasonable steps to verify the identity of the person making the request, which may include a requirement for the requestor to produce valid identity documentation. If the request is made by an authorized representative, they must provide proof of such authority. If VegaLeap be unable to confirm the identity or authorization of the requestor, then we are not required to comply with the request.
Response Timing and Format
Requests Made Pursuant to CCPA/CRPA (“Verifiable Consumer Requests”)
Upon receipt of a Verifiable Consumer Request, VegaLeap will: (i) acknowledge receipt and send the requester information regarding our procedures for verifying and processing such requests within ten (10) business days; and (ii) respond to the request within forty-five (45) to ninety (90) calendar days. If we need more than 45 calendar days to process your request, we will notify you of the extension and the reason in writing.
VegaLeap maintains comprehensive records of consumer requests made pursuant to the CCPA/CRPA, along with any associated correspondence, for a minimum period of twenty-four (24) months.
Requests Made Pursuant to EEA or UK Data Protection Laws (“Data Subject Requests”)
Upon receipt of a Data Subject Request, VegaLeap will acknowledge receipt of the request without undue delay and respond to the Request within one (1) month. If we require more time (up to two additional months) due to the complexity or number of such requests, we will inform you of this extension and the reason(s) for the delay within one (1) month of receiving the request.
VegaLeap maintains detailed records of all Data Subject Requests, along with any associated correspondence, for a period deemed necessary to facilitate our compliance functions.
Important Information Regarding Verifiable Consumer Requests
A response to a Verifiable Consumer Request will only encompass information from the twelve (12) month period immediately preceding the date of receipt of the request. We take any and all reasonable measures to fulfill a verified request to the extent permitted by law.
In situations where Personal Information collected about you is eligible for deletion and has been previously shared with third-party service providers, we will instruct these entities to remove such information from their records. If we or our service providers require any Personal Information collected about you that is eligible for deletion for purposes of: (i) sustaining a business relationship; (ii) facilitating a transaction; (iii) fulfilling a contractual obligation; (iv) exercising free speech; or (v) ensuring the security of our Site or services, then we will not proceed to delete such information.
Important Information Regarding Your Data Subject Request
We reserve the right to charge you a reasonable fee or refuse to grant your Data Subject Request if we deem it to be manifestly unfounded or excessive or repetitive in nature.
Additional Privacy Disclosures for Investors and Transactions
Please note that this privacy policy applies only to information collected about you through your interaction with our Site. If you invest in any of VegaLeap’s funds, engage in any transactions with us or engage in any correspondence with us as an investor, then the collection, retention, use and disclosure of any personal information collected about you during the course of these activities is governed by separate privacy disclosures. Such disclosures can be found, among other locations, in the offering documents or other transaction-related materials provided to you during the investment or transaction process. We encourage investors and those with whom we conduct transactions to review these documents carefully to understand how personal information collected about you is handled in those contexts.
CONTACT US
If you have any questions, comments or concerns about this Privacy Policy, please contact us at: privacy@vegaleap.com