Information the Firm collects
From Investors and prospective Investors. CC collects nonpublic personal information from subscription documents, Investor questionnaires, and other Fund documents, and from Investors’ transactions with the Funds. This may include (but is not limited to):
- Name, address, email address, and telephone number
- Social Security or tax identification number and date of birth
- Income, assets, net worth, and other information used to confirm eligibility to invest
- Bank account and wire instructions
- Capital commitments, contributions, distributions, and capital account balances
From business contacts. CC collects information about founders, portfolio company contacts, co-investors, event attendees, and applicants for positions at CC, such as name, title, company, and contact details. This information comes from the individuals themselves and from public sources, such as company websites and LinkedIn.
From website visitors. CC collects information in two ways when you use this website:
- Information you provide, such as your name, email address, telephone number, and postal address, when you contact CC
- Log data that your browser sends automatically, such as your IP address, browser type and version, the pages you visit, the time and date of your visit, and the time spent on those pages
How the Firm uses information
CC uses Investor information to process investments, administer Investors’ interests in the Funds, communicate about the Funds, and meet legal and regulatory requirements. CC uses business contact information to evaluate potential investments, manage portfolio relationships, host events, and consider applicants for positions at CC. CC uses information from website visitors to respond to inquiries, contact or identify you, and operate and improve this website.
How CC shares information
CC does not sell personal information. CC does not disclose, and does not reserve the right to disclose, nonpublic personal information about current, prospective, or former Investors except as permitted by law, including:
- Service providers that help CC administer the Funds, such as fund administrators, banks, auditors, and legal and tax advisers, under written agreements that require them to protect the information and use it only to perform services for CC
- Regulators and law enforcement, and in response to subpoenas, court orders, or legal investigations
- Parties you authorize, only with your consent
- A buyer or successor, in connection with a merger or sale of all or part of CC’s business
CC does not share Investor information with affiliates or third parties for marketing purposes. Because the Firm shares information only as the law permits, Investors do not need to opt out. If this ever changes, CC will update this policy and allow Investors to opt out before any information is shared.
How CC protects information
CC maintains physical, electronic, and procedural safeguards designed to protect personal information, including:
- Limiting access to employees who need the information to do their jobs
- Requiring multi-factor authentication and encrypting information sent outside the Firm’s systems
- Requiring service providers to protect information and to notify CC within 72 hours of any security breach
- Securely shredding paper records and wiping electronic media before disposal
- Training employees on information security at least annually
No method of transmitting information over the internet or storing it electronically is completely secure, so CC cannot guarantee absolute security. CC keeps personal information as long as needed for the purposes described in this policy and as required by law.
If an Investor’s sensitive information is accessed or used without authorization in a way that is reasonably likely to cause substantial harm or inconvenience, the Firm will notify the affected Investor in writing as soon as practicable, and no later than 30 days after learning of it. The notice will describe what happened and the steps the Investor can take to protect against identity theft.
Cookies and third-party links
Cookies are small data files that a website stores on your computer. CC and its website hosting and analytics providers use cookies and similar technologies to collect information about how visitors use this website and to operate and improve it.
You can set your browser to refuse cookies or to alert you when a cookie is sent, although some features of this website may not work properly if you do. This website does not respond to “Do Not Track” signals.
This website uses Google Analytics, a service provided by Google, to collect information about website usage, such as pages visited, browser and device characteristics, and visitor interactions. For more information about how Google collects and processes this data, please see How Google uses information from sites or apps that use our services. You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.
This website also loads fonts from Google Fonts, a service provided by Google. When you visit this website, your browser connects to Google’s servers to retrieve these fonts, which sends your IP address to Google.
This website may contain links to third-party websites, including job application platforms for positions at CC and at CC’s portfolio companies. CC does not control and is not responsible for the content or privacy practices of those websites, which are governed by their own privacy policies. Information you submit through a job application platform for a position at CC is collected by that platform and is subject to its privacy policy, in addition to this policy once CC receives it. Applications for positions at CC’s portfolio companies go directly to those companies. CC does not receive or have access to them.
Children’s privacy
This website is intended only for adults 18 and older and is not directed to children under 13. CC does not knowingly collect personal information from children under 13. If CC learns that it has received such information, it will delete it promptly. A parent or guardian who believes a child has provided information to CC should contact the Firm using the information below.
Your choices
You may ask to review, correct, or delete the personal information CC holds about you, subject to CC’s legal and regulatory recordkeeping obligations. Regardless of any changes, Investors will continue to receive communications required for their investment in the Funds.
Changes to this policy
CC reviews this policy at least annually. Changes to website practices take effect when posted on this website, and the “Last Updated” date above will show when the policy was last revised. If CC changes its practices for Investor information, it will send Investors a revised policy before the change takes effect.
No offer or solicitation
Nothing on this website or in this policy is an offer to sell, or a solicitation of an offer to buy, any security, including any interest in a Fund. Any such offer will be made only to qualified investors through a Fund’s confidential offering and subscription documents, and only as permitted by law. Interests in the Funds have not been registered under the Securities Act of 1933 or any state securities laws. Information on this website is for general informational purposes only and is not investment, legal, or tax advice.
Questions
To ask a question or request your information, contact:
Caleb Eidem
General Counsel and Chief Compliance Officer
Cultivation Capital, LLC
ceidem@cultivationcapital.com
