SmartData

Effective Date: April 2019

Privacy Policy

This Privacy Policy (“Privacy Policy”) applies to any and all information that VC Digital Lab, Inc., a Delaware corporation (“SmartData”), may obtain in the course of your use of its websites, products or services, including its SmartData platform (collectively, “Services”) and during the performance of any agreements and contracts with you. This Privacy Policy informs you of our policies regarding the collection, use and disclosure of personal data when you use the Services and the choices you have associated with that data. By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy.

INFORMATION COLLECTION AND USE

We collect information from you (1) when you register on our site and, (2) during the normal course of use of the Services.

Types of Data Collected

Personal Data

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address

• Phone number

• Username

• Password

• First name and last name

• Any other information you give us through the Services

If you are a subscriber to our paid services, we will also collect your billing details such as credit card information, banking information, and/or billing address.

Non Personal Data

Through your use of the Services, we will collect additional “Non-Personal Information.” This information may include, but is not limited to, the following:

• Portfolio Company name

• Portfolio Company description

• Portfolio Company website address

• Portfolio Company Shareholders and related personal information

• Portfolio Company Shareholder ownership stakes in the company

• Any documents that you see fit to upload into the SmartData platform

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies we use:

• Session Cookies.  We use Session Cookies to operate our Service.

• Preference Cookies.  We use Preference Cookies to remember your preferences and various settings.

• Security Cookies.  We use Security Cookies for security purposes.

USE OF DATA

SmartData uses the collected data for various purposes:

• To assist in setting up and maintaining your account

• To personalize your experience

• To provide and maintain our Services

• To notify you about changes to our Services

• To allow you to participate in interactive features of our Service when you choose to do so

• To provide customer support

• To carry out statistical and other kinds of research and analysis based on anonymized data

• To monitor the usage of our Services

• To detect, prevent and address technical issues

• To improve the quality of the Services, convenience of their use, develop new Services

• To identify a party using the Services or a party to an agreement or contract with SmartData

LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are from the European Economic Area (EEA), SmartData’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

SmartData may process your Personal Data because:

• We need to perform a contract with you

• You have given us permission to do so

• The processing is in our legitimate interests and it is not overridden by your rights

• To comply with the law

RETENTION OF DATA

SmartData will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

SmartData will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

TRANSFER OF DATA

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

SmartData will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

DISCLOSURE OF DATA

Legal Requirements

SmartData may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation

• To protect and defend the rights or property of SmartData

• To prevent or investigate possible wrongdoing in connection with the Service

• To protect the personal safety of users of the Service or the public

• To protect against legal liability

SECURITY OF DATA

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. SmartData aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or delete the information we have on you.  Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

• The right of rectification.  You have the right to have your information rectified if that information is inaccurate or incomplete.

• The right to object.  You have the right to object to our processing of your Personal Data.

• The right of restriction.  You have the right to request that we restrict the processing of your personal information.

• The right to data portability.  You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

• The right to withdraw consent.  You also have the right to withdraw your consent at any time where SmartData relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us to analyze how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

CHILDREN'S PRIVACY

We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not knowingly collect any information from anyone under 13 years of age. Nor do we authorize children under 18 years of age to use our Service. Our website, products and Services are all directed to people who are at least 13 years old or older.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

CONTACT US

Any questions or suggestions regarding this Policy may be addressed by you to VC Digital Lab, Inc., 541 Jefferson Ave, Ste 100, Redwood City, CA 94063, USA, privacy@smartdata.vc