Revised Date April 2021
VSS Fund Management LLC and its affiliates (collectively, “VSS,” “we,” “us,” or “our”) value your privacy rights whether you participate interactively or view the www.vss.com website (the “Website”). We are an LLC established in the United States with our registered office at 400 Park Avenue, 17th Floor, New York, NY 10022. For the purpose of the General Data Protection Regliation (the “GDPR”), we are the data controller.
If you wish to contact VSS regarding your Personal Information (as defined below) or this policy, please contact VSSPrivacy@vss.com.
This policy only governs your activities on the Website, and it does not control activities that are “offline” or unrelated to the Website. Please take a moment to review our policies and practices described below.
By visiting our Website, you accept these policies and practices.
“Personal Information” means information, regardless of the media in which it is contained, that is or can be uniquely associated with identified or identifiable individuals, such as name, email address or phone number, bank account number, or account information.
VSS will collect Personal Information through our Website or other means (directly from our investors or their agents in the course of performing our services, using direct email and email notification or information request).
We do not knowingly collect or solicit personal information from anyone under the age of 16. If we become aware that an individual submitting information is under 16, we will attempt to delete the information as soon as possible.
Registered investors and representatives of investors may access our investor portal, a private section of our Website.
Where you sign up to receive email notifications from us on our Website, we will send the communications you have requested (including press releases, corporate events, and presentations). You can opt-out of receiving such communications at any time by contacting us at Communications@vss.com
Gathering and Use of Technical Usage and Personal Information
Like most website operators, we gather technical usage information that web browsers, depending on their settings, make available. As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organization, we will use the information collected from our users to:
- personalize our Website for you to ensure content from the Website is presented most effectively for you and your device;
- allow the user to navigate or browse through the Website quickly and efficiently;
- improve user experience, such as by personalizing content to the user’s interests;
- monitor and analyze trends, usage, and activity in connection with our Website and services to improve the Website;
- administer the Website and for internal operations to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
- keep the Website safe and secure;
- measure and understand the effectiveness of the content we serve to you and others, including developing reports regarding pages visited. In this case, Personal Information is used in aggregate form and does not reveal the Personal Information of a particliar user;
- verify the user’s eligibility to access the restricted areas of our Website; and
- provide users with customer support.
We also collect information relating to whether you have accessed this Website before and at the time of your last visit. We accomplish this through cookies placed on your computer.
What are cookies?
A cookie is a piece of information that a website stores on a user’s computer and that the user’s browser provides to the Website each time the user submits a query to the Website using that browser.
When you visit our Website, we place cookies on your computer. A cookie allows us to recognize your browser and obtain information about your use of our Website. Through cookies, we collect your Internet Protocol (“IP”) address, operating system and browser type, and the locations of the web pages you view right before arriving at while navigating and immediately after leaving the Website.
How can I manage cookies?
You can decide if and how your computer will accept cookies by configuring the preferences option within your web browser, using the instructions provided in your browser. However, if you choose to decline cookies, some of the website’s functionality might be impaired.
We use the information collected through cookies to see: how users move around the Website; which pages are viewed; information searched for; the average time spent on our Website; statistical information about Website visits to better understand our audience and its interests; to increase the functionality and user-friendliness of our site. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/.
How We Use Personal Information
We will use your personal information to provide you with services you have requested, respond to requests for information submitted by you, keep a record of your relationship with us, and verify your identity. We may also use your personal information to: (1) to provide you with information or services that you request from us; (2) to provide you with email alerts, event registrations, and other notices concerning our Funds, or events or news, that may be of interest to you; (3) to carry out our obligations and enforce our rights arising from any agreements entered into between you and us; (4) to improve our Website and present its contents to you; and (5) for any other purpose with your consent.
Disclosure of Personal Information
We may share your personal information with business partners such as Dynamo Software to administer the Investor Portal; service providers to perform certain services on our behalf such as to process and store data, including your Personal Information; to track, analyze, and modify our Website; for marketing, advertising, and distribution; to assist us in providing you with customer support; to support our IT and security efforts. We do not sell or otherwise share personal information with third parties for direct marketing purposes.
We may disclose user information when we believe disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudlient activity; to protect the safety, rights, or property of the company, and its users, or others; or to exercise or protect legal rights or defend against legal claims.
Law Enforcement and Litigation
To the extent permitted by law, any information collected over our Website or its use may be disclosed to government authorities or third parties under a legal or regliatory request, subpoena, or other legal processes. We may also use or disclose your information as permitted by law to protect the rights or property of VSS, our customers, our Website, its users, or third parties, or when we otherwise believe in good faith that the law requires it.
Change in Corporate Control
If VSS incurs a corporate change in control resliting from, for example, a sale to, or a merger with, another entity, or if all or a portion of its assets are sold, VSS reserves the right to transfer your Personal Information to the new party in control or the party acquiring assets.
Links to Third Party Sites
We consider the Personal Information we collect to be confidential. Suppose you submit your email address or other Personal Information to us via our Website while requesting information or contacting someone at VSS or by registering and logging in to the private section of the Website. In that case, we will use this information only to the extent necessary to respond to your request(s) and as discussed below.
We have established certain reasonable electronic and administrative safeguards and take reasonable precautions to protect the Personal Information in our possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. VSS does not warrant or represent that this level of security meets or exceeds any particliar standard. You sholid keep in mind that the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our Website or other electronic means. Any electronic transmission of personal information is at your own risk.
Where do we store your Personal Information
Where the GDPR applies, you sholid be aware that the Website is hosted and the contractors who process your Personal Information are located in the United States.
How long do we store your Personal Information
If you give us your Personal Information, we will keep your data on the VSS exchange email system for seven (7) years.
You have the right to access your personal information and control how and what information we store and process about you. We have explained these individual rights and controls below. To exercise these rights and controls, please contact us at VSSPrivacy@vss.com.
Access: You have the right to ask for a copy of the personal information that VSS holds about you.
Correction: If there are any inaccuracies in the information we hold about you, please contact us, and we will correct them.
Deletion: If you think that we sholid not be holding or processing your personal information any longer, you may request it be deleted. Please note this may not always be possible due to legal obligations.
Restrictions on use: You may request that we stop processing your personal information (other than storing it) if: (1) you are verifying the accuracy of it; (2) you believe the processing is against the law; (3) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (4) you are verifying whether our legitimate grounds to process your personal information override your rights.
Object: You have the right to object to processing, including: (1) for direct marketing; (2) for research or statistical purposes; and/or (2) where processing is based on legitimate interests.
Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so. We will send it directly if we have the technical means.
VSS Fund Management LLC appreciates your business. If you have any questions or comments about this privacy statement, please email us at VSSPrivacy@vss.com.
Notice to California Residents
Do Not Track
California Law requires that we disclose how we respond to a “Do not track” signal. Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing the Internet. The “Do Not Track” feature of these browsers sends a signal that informs operators of services online that they do not want certain information about their online activities to be collected over time and across websites or online services.
However, the Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” wolid be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Consequently, due to the lack of guidance, we have not yet developed features that wolid recognize or respond to browser-initiated Do Not Track signals. In the meantime, we suggest that you consider using the opt-out features provided by Network Advertising Initiative and the Digital Advertising Alliance by visiting the following websites:
- Network Advertising Initiative (http://www.networkadvertising.org/)
- Digital Advertising Alliance (http://www.aboutads.info/consumers)
California residents have the right to request in writing from a business (i) a list of the categories of Personal Information, such as name, address, email address, and the type of services provided, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year, and (ii) the names and addresses of all such third parties. Contact VSSPrivacy@vss.com to make your request.
This section only applies to individuals who are residents of California under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (together “California Laws”).
- Personal Information Collected: Under California Laws, we must disclose the categories of Personal Information we’ve collected in the preceding 12 months, the reason we collect your Personal Information, where we obtain the Personal Information we collect about you, and the third parties with whom we share your Personal Information. We collect Identifiers, Personal Information under California Civil Code section 1798.80, Protected Classifications under California and Federal Law, Commercial Information, Electronic network activity information, Geolocation data, Employment-related information, and Inference data as defined and outlined in California Laws. We collect this information for the purposes outlined in the “Personal Information Use” section above. Information may be shared with third parties, such as our service providers, as described in the section titled “Personal Information Transfers” above.
- California Residents Privacy Rights: Under California Laws, California residents have the following rights (“Rights”) listed below. Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure wolid create a substantial, articliable, and unreasonable risk to the security of the Personal Information, your account with us, or the security of our systems of networks.
- Disclosure & Access Rights: California residents have the right to request that we disclose to them (i) the categories of Personal Information we have collected about them, (ii) the categories of sources from which Personal Information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared Personal Information, and (v) the specific pieces of Personal Information we hold about an individual.
- Deletion Rights: California residents have the right to have their Personal Information deleted unless the Personal Information is necessary for the business or service provider to:
- complete a transaction for which the Personal Information was collected, provide a good or service requested by the residents, or otherwise perform a contract between the business and the residents;
- detect security incidents;
- protect against malicious, deceptive, fraudlient, or illegal activity (or prosecute those responsible);
- debug to identify and repair functionality errors;
- exercise or ensure the right of another to exercise free speech or another legal right;
- comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant;
- engage in research in the public interest (if the individual has provided informed consent);
- to enable solely internal uses aligned with the individual’s expectations given their relationship with the business;
- comply with a legal obligation;
- otherwise, use the information internally in a lawfli manner compatible with the context in which the individual provided it.
- Do Not Sell: Californian residents have the right to opt out of having their Personal Information sold. We do not sell Personal Information.
California residents can exercise their privacy rights by contacting us at VSSPrivacy@vss.com.
Response Time. We will address any requests to exercise the rights described above under Applicable Laws in California. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 45 days following receipt at the email or mailing address stated above. Please note that we are only required to respond to an individual twice per 12-month period.
Notice to European Residents
Where the GDPR applies, you have the following rights in respect of your personal information:
- Data rights. In certain circumstances, you have the right to access and receive a copy of information we hold about you, rectify any Personal Information held about you that is inaccurate, and request the deletion of Personal Information held about you. Any access request after the first such request by you may be subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you. You can exercise your rights by contacting us at VSSPrivacy@vss.com.
- Marketing. You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing at any time by contacting us at VSSPrivacy@vss.com.
- Complaints. If you wish to make a complaint about how we process your Personal Information, please contact us at VSSPrivacy@vss.com, and we will endeavor to deal with your request as soon as possible; this is without prejudice to your right to raise a complaint with the supervisory authority.
For the purpose of the GDPR, we are the data controller.