Privacy

Alameda Capital Management LLC. and our affiliates (together, “our”, “we”, “company” or “Alameda Capital”) are committed to respecting the privacy of all users of our website at www.alamedacap.com (the “Site”). We have established and implemented this Privacy Policy to inform you, the user of the Site, of the type of information collected by us and how we use and protect such information. Please read this Privacy Policy carefully.

Except where EU laws apply to the processing of your personal information, by providing your personally identifiable information to us, you signify your acceptance of this Privacy Policy and agree that we may collect, use and disclose your personally identifiable information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not provide your personal details to us.

This Privacy Policy is incorporated into, and part of, the Terms of Use, which govern your use of the Site in general.

Alameda Capital reserves the right to amend this Privacy Policy in its sole discretion from time to time. Alameda will post any changes to this Privacy Policy on the Site so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it, and such changes shall be effective immediately upon posting. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. Except where EU laws apply to the processing of your personal information, your provision of personally identifiable information after any such changes constitutes your acceptance of the new terms and conditions.

We will use information only in accordance with the Privacy Policy under which the information was collected.

For the purposes of applicable EU laws, Alameda Capital Management LLC. will be a data controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this Privacy Policy, please contact Alameda Capital Management LLC. at +1 (415) 813.7798 or at privacy@alamedacap.com.

Table of Contents

• Information We Collect
• How We Use Information Collected
• Marketing
• With Whom Do We Share the Information We Collect?
• CCPA Consumer Rights
• Transfers of Personal Information Outside the EEA
• Security
• Capacity
• Cookies
• Your EU Rights

Information We Collect

Information you provide to us

In general, you can visit the Site without telling us who you are or revealing any information about yourself.

We collect your personal information when you decide to interact with us and which you submit using the contact options provided on this Site. You can also provide us with personal information via email, post and telephone. This may include your name, email address, address, title, job title, position, telephone number and IP address. We may collect additional personal information about you, including special categories of personal information, when you apply for a job with Alameda or an affiliate or enter into an agreement with Alameda Capital. See below for further information on 'How We Use Information Collected'.

Information provided by third parties or publicly available sources

We collect personal information about you from third parties including from our affiliates, our portfolio companies, job posting websites and recruiting firms, and companies that we are evaluating in connection with a potential investment or business opportunity.

Information provided under a legal obligation

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations). Failure to provide this information may mean that we cannot provide our services or products to you. In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.

How We Use Information Collected

To the extent that you provide us with any personal information, through or in connection with this Site (i.e., via telephone, email or post), we may use such information for the following purposes:

How We Use Information Collected

To the extent that you provide us with any personal information, through or in connection with this Site (i.e., via telephone, email or post), we may use such information for the following purposes:

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal information.

Marketing

We will send you direct marketing communications where we have obtained your prior consent to keep you informed of our services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to certain kinds of marketing at any time by emailing marketing@alamedacap.com.

With Whom Do We Share the Information We Collect?

Your personal information will be shared with and processed by:

• our affiliates
• certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including professional advisors, recruitment firms, consultants and data hosting providers

We use our best efforts to ensure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.

We reserve the right to disclose your personal information to third parties in order to comply with law, to law enforcement or other governmental agencies, or when we believe that disclosure is necessary to enforce or protect our rights in or otherwise with respect to, or the safety of, our Site, or to protect the safety or rights of other users of our Site and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors.

CCPA Consumer Rights

California: Your Privacy Rights

If you are a California resident, you may have the right to (1) request access to certain personal information we have collected about you, (2) request that we delete certain personal information we have collected from you and (3) opt-out of the sale of your personal information.

To view our California Consumer Privacy Statement, click here.

Transfers of Personal Information Outside the EEA

Your personal information will be hosted in the U.S. and will therefore be transferred and stored outside of the European Economic Area (“EEA”), where collected in the EU. For the purpose of applicable EU laws, such third countries (including the U.S.) may not offer the same level of data protection as your country of residence. Such transfers will be made in accordance with applicable EU data privacy laws. For further information about the safeguards used, please contact privacy@alamedacap.com.

Security

We are committed to protecting the personal information you entrust to us. We implement appropriate security measures and technologies to seek to ensure the security of your personal information on our systems and to ensure that it is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Notwithstanding our efforts to protect your information, no security system is completely impenetrable, so we cannot guarantee the absolute security of our databases, nor can we guarantee that information you supply to us will not be intercepted while in transit to us over the Internet. Any transmission of information or data by you to or through this Site is at your sole risk.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact privacy@alamedacap.com.

Capacity

This site is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.

Cookies

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.

You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Incapsula

Onetrust Cookie Consent

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site.

All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Marketo

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

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Your EU Rights

To the extent that EU data protection laws apply to the processing of your personal information, or to the extent that you are a resident of the UK, the EU or the EEA, you have certain rights with respect to your personal information, as outlined below.

You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact privacy@alamedacapital.com.

• Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a 'reasonable fee', if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
• Correction: You may notify us of changes to such your personal information if it is inaccurate or it needs to be updated.
• Deletion: If you think that we shouldn't be holding or processing your personal information anymore, you may request that we delete it. Please note that 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: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) 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 (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) 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, and we will send it directly if we have the technical means.
• Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office. You can find details for your relevant EU national data protection authority here.

California consumers

This California Consumer Privacy Statement supplements the Privacy Policy and applies solely to California consumers. This Statement does not apply to (i) Alameda personnel or job applicants seeking opportunities at Alameda, (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, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), 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, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, 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
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• 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 certain business or commercial purposes, as described in this table:

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, (c) the categories of personal information we may have sold, and (d) 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.

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

c. Sale of Personal Information

We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our site in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you).  You have the right to opt out of this disclosure of your information, as detailed below.

During the 12-month period prior to the effective date of this California Consumer Privacy Statement, we may have sold the following categories of personal information:

• Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
• 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
• 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 do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

d. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties the following categories of personal information for a business purpose:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), 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, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information
• Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
• Commercial Information: commercial information, including records of personal property, products or 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
• Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• 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.

3. California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold 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.

Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.

Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.

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 have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide additional information, including submitting a code that has been sent via email to the email address you provided. In addition, if you do not have an account and 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, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and (2) for access and deletion requests, we may require you to 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@alamedacap.com to request this Statement in an alternative format.

Please use the form below if you would like to make a request on your own behalf. If you would like to submit a request as an authorized agent on behalf of another individual, please email privacy@alamedacap.com.