Privacy Policy

Moneta Ventures, LLC. (“Moneta”, “Moneta Ventures”, “we”, “us”, “our”) understands and respects our users’ need for privacy. This Privacy Policy covers the information that we may collect or receive about users who visit www.moneta.vc and other websites owned and operated by us (including our client and user interfaces) or download and/or install our mobile application(s) or otherwise use our services (collectively, the “Services”). This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), such as our investors and any service providers. See “Third Parties” below for more information.

By using or accessing the Services or providing us with your information, you represent that you are at least 18 years old and you consent to our processing of your data as set forth in this Privacy Policy now and as amended by us.  For information on how we may change our Privacy Policy, please read “Changes to this Privacy Policy” below.

If you have any questions about this Privacy Policy, please see the “Contacting Us” section below.

Please review the jurisdiction-specific provisions below for more information if you are located in Europe or California.

This Privacy Policy will cover the following sections:
- Collecting information
- Using information
- Sharing information
- Cookies and similar technologies
- Retaining information
- Protecting information
- Children’s information
- Sensitive information
- User’s rights
- Choices
- International data transfers
- Third-party services, applications and websites
- Changes to this privacy policy
- Contacting us
- Additional disclosures for European users
- Additional rights of California users

‍Collecting Information
‍We and our third-party service providers may collect your information about you, including the following:
- Identifiers such as name, email address, phone number, social media accounts; mobile device identifier;
- Geolocation information;
- Internet or other electronic network activity information such as browser information, time spent on the Services and your activities on the Services, pages visited, requested URL and referring URL, date and time on the Services, information about interactions with our emails, and other anonymous traffic-related data;
- Transaction-related data such as: date, time and location a transaction took place, description and/or classification of the transaction, unique identification numbers, including IP address and your location derived from IP address, demographic information (e.g., date of birth, gender) as provided by you;
- Information to enable and authorize your logging in to the Services;

We and our third party service providers may collect or receive this information in a variety of ways:
- Directly from you;
- Automatically through your browser or device, your mobile device identifier, your use of our Services, your IP address, or the use of cookies and other similar technologies; and
- From our business customers or service providers.

‍Using Information
‍We and our third-party service providers may use your information:
- To operate, improve, analyze and manage the Services;
- To ensure the Services function properly;
- To respond to your inquiries and fulfill your requests and process users’ accounts;
- To evaluate investment potential;
- To send administrative information to you;
- To send you communications that we believe may be of interest to you, including any communications for marketing purposes related to the Services for our business purposes, such as tracking conversion of prospective customers into actual customers, data analysis, fraud monitoring prevention and security, developing new products, enhancing, improving or modifying our Services, identifying usage trends, and determining the effectiveness of our Services; and
- As we believe to be necessary or appropriate:
a.    under applicable law;
b.    to comply with legal process and our legal obligations;
c.    to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties;
d.    to enforce our terms and conditions;
e.    to protect our operations and the security of our Services;
f.     to protect our rights, privacy, safety or property, and/or that of you or others;
g.    to allow us to pursue available remedies or limit the damages that we may sustain; and
h.    to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

We may partner with certain third parties to collect other information to engage in analysis, research, and reporting of Service usage patterns. These third parties may also deliver advertising to you on other websites and applications, based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices and may also use web logs or web beacons.

‍Sharing Information
‍We may share your information:
- among our affiliates for the purposes described in this Privacy Policy (Moneta is the party responsible for the management of the information jointly used by it and its affiliates);
- with our investors who use our Services so that investors can analyze the effectiveness and performance of our Services;
- with our service providers who provide services such as email management, transaction management, campaign measurement, hosting and storage, web serving, performance tracking and reporting, technical services, marketing analytics and other services;
- directly by you in your account and other services to which you are able to post information and materials publicly yourself (including, without limitation, our and your social media pages);
- with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
- as we believe to be necessary or appropriate:
a.    under applicable law;
b.    to comply with legal process and our legal obligations;
c.    to respond to requests or requirements from public, law and government authorities (including national security and law enforcement requirements) and private parties;
d.    to enforce our terms and conditions;
e.    to protect our operations and the security of our Services;
f.     to protect our rights, privacy, safety or property, and/or that of you or others;
g.    to allow us to pursue available remedies or limit the damages that we may sustain; and
h.    to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

We ask our service providers to confirm that their privacy and security practices are consistent with ours, we provide our service providers with only the information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by Moneta.

Our service providers who provide usage analytics for our Services may also use your information to provide you with more personalized advertising content on other websites and applications. To opt out of interest-based advertising by third parties, see “Choices.”

‍Moneta may offer online resources that facilitate communications among the Moneta community and others. Whenever you voluntarily post information to any public forum offered by Moneta, such information along with your username can be accessed by other users of the forum, including members of the public if the forum is open to the public.

‍Cookies and Similar Technologies
‍A cookie is a small data file that is stored on your computer’s or mobile device’s memory. Some cookies help you navigate our Services, including setting a cookie to remember your login details. Our cookies are linked to your login information so that you can use the Services on your device throughout the day without logging in each time you visit the Services. Cookies also help us better understand the effectiveness of our Services (for example, by tracking the way in which you respond to, select and interact with our Services). Other cookies collect information about how you use our Services, which highlights areas we can improve, including navigation.  

Third parties may use cookies or similar technologies on visitors of our Services to serve interest-based advertisements to such visitors when they visit other websites and mobile applications. The collection of information through cookies or similar technologies by such third parties will be governed by such third parties’ own privacy policies and principles, which Moneta does not control. To opt out of interest-based advertising by third parties, see “Choices.”

‍For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu. To read about your choices with regard to Moneta’s and third parties’ uses of cookies in our Services, please see “Choices.”

‍We and our service providers may also use “pixel tags,” “web beacons”, “clear GIFs” or similar means (individually or collectively “Pixel Tags”) to analyze usage patterns of consumers. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tags allow us to count users who have visited certain websites and applications of our business customers, and pages within such websites and applications, and to help determine the effectiveness of marketing campaigns.

We do not respond to Do Not Track (DNT) signals at this time.

‍Retaining Information
‍We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, or an individual or business customer requests deletion in accordance with applicable law.

‍Protecting Information
‍Information that we collect is stored using procedures and practices reasonably designed to help protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us. Despite our efforts to keep your information secure, we cannot guarantee that unauthorized parties will not gain access to your personal information.

‍Children’s Information
‍Our Services are not intended for, nor directed to, individuals under the age of 18, and we request that these individuals, and any other individual considered a minor under applicable law, not provide personal information through any of our Services. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@moneta.vc. If we become aware that a child under 18 (or under the legal age under applicable law) has provided us with personal information without parental consent, we will take steps to remove such information and terminate the child’s account.

‍Sensitive Information
‍We ask that you not send us, and you not disclose to us, any sensitive information (e.g., social security numbers or other government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, medical or health conditions, criminal background, trade union membership, or sexual orientation) on or through the Services or otherwise to us, except where such information is legally required.

‍User Rights
‍We give you choices regarding our use and disclosure of your personal information for marketing. You may contact us as indicated under the “Contacting Us” section below and request that we provide you with a copy of your personal information or that we correct or delete your personal information that we maintain on our systems. We will respond to your request within a reasonable timeframe.

If you are a European user see “Your Rights as a European User” below.

If you are a California user, see “Additional Rights of California Users” below.

‍Choices
‍Opting Out of Marketing
‍We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at privacy@moneta.vc or by clicking on the opt-out link within the email message that you receive from us. Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.

‍Opting Out of Moneta’ Cookies
‍You may disable cookies, including Moneta’ cookies, by modifying the settings in your browser. However, please note that if you delete or disable cookies, you will not be able to stay logged in to the Services and, as a result, the Services will no longer be available to you. Our cookie is required to provide some of our Services. Our cookies are linked to your login information so that you can use the Services on your device throughout the day without logging in each time you visit the Services.

‍Opting Out of Interest-Based Advertising by Third Parties from Cookies
‍Some third parties who use cookies when you visit our websites, have opt out mechanisms either directly from their website or through an industry-developed web page. If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes. When you opt out of receiving interest-based advertising from third parties, note that the opt out only applies to the applicable browser in which you set it. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.eu. Third parties may also combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, please follow the instructions above for opting out on each of your browsers, and also opt out on each of your mobile devices. Please note that you will need to opt out separately on (1) each of your browsers and (2) each of your mobile devices to ensure that information collected on a particular browser or device is not used on another browser or device.

‍Opting Out of Use of Precise Location
‍To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.
- Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).
- iOS: In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.
You may deactivate your account by changing your preferences in the user settings page of the Services.

‍International Data Transfers
‍Please be aware that the information we collect may be transferred to and maintained on servers or databases located outside your country, where the privacy laws may not be as protective as those in your country. Please be advised that we process and store information in any country where we have facilities and/or employees, including the United States, or in which we engage service providers. Your consent to this Privacy Policy or your use of any of the Services or your submission of your information to us or any of our business customers, represents your consent to such transfer, storage and processing outside of your country of residence, including the United States, which may have different data protection rules than those of your country of residence.
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‍Model Clauses: If you are located in the European Economic Area, the United Kingdom or Switzerland, we will protect your personal information when it is transferred outside of your jurisdiction by (a) processing it in a territory that provides an adequate level of protection based on its data protection laws; or (b) implementing appropriate safeguards to protect your personal information, such as relying on the European standard contractual clauses. Moneta currently relies on these European standard contractual clauses for data transfers.

‍Third-Party Services, Applications and Websites
‍This Privacy Policy does not cover, and we are not responsible for, the privacy, data or other practices of any third parties (except as required by applicable law), including any third parties operating any site or service to which our Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates. These third parties are bound by their own privacy policies.

Except as required by applicable law, we are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of our service providers, app developers, app providers, ad servers, social media platform providers, including any personal information you disclose to other organizations through or in connection with the Services.

‍Changes to this Privacy Policy
‍We reserve the right to make changes to our Privacy Policy. Please look at the date at the top of this page to see when this Privacy Policy was last revised. Where required by law, we will obtain your consent to make these changes.

‍Contacting Us
‍For any questions about this Privacy Policy or Moneta’ privacy practices, please contact us by email at privacy@moneta.vc, or by mail at:

Moneta Ventures, LLC.
Attn: Privacy
785 Orchard Drive
Suite 150
Folsom, CA 95630
USA

‍Additional Disclosures for European Users
Legal Basis for Processing Personal Information for European Users
‍Moneta is a data processor with respect to personal data collected or received by us when we receive such information from: our investors and prospective and current portfolio companies (the data controllers) that make their data available for use via our Services. Where we operate as a data processor, we are processing the data on behalf of our investors and prospective and current portfolio companies (the data controller(s) of the data), and it is the responsibility of the data controller to establish an appropriate legal basis for the processing of the data.

For example, we may process data when the individual has consented to such processing. On certain occasions we may rely on another lawful basis as a basis for processing, such as when it is in our investors and prospective and current portfolio companies’ and our legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include performing our obligations with respect to providing the Services and improving our Services.

Moneta is a data controller with respect to any personal data collected or received by us when we receive personal information (such as name, phone number, and email address) through our Services without being connected to any business customer. In this case, the data controller is Moneta. Where Moneta operates as a data controller, we rely on legitimate interests to process personal data to provide our Services. On certain occasions, we may also rely on the consent of the individual to process personal information (for example, in some jurisdictions, when the user inputs personal information into the Services and consents to receive marketing communications). On other occasions, we may process personal information when we need to do this to fulfill a contract or where we are required to do so by law.

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@moneta.vc.

Your Rights as a European User
‍If you are located in the European Economic Area, the United Kingdom or Switzerland, you may have rights under data protection laws in relation to your personal information, such as:
- The right to be informed,
- The right of access,
- The right to rectification,
- The right to erasure,
- The right to restrict processing,
- The right to data portability,
- The right to object,
- The right to lodge a complaint with a supervisory authority, and
- Rights in relation to automated decision making and profiling.

To exercise any of these rights, email us at privacy@moneta.vc with your request. We will handle your request under applicable law. When you make a request, we may verify your identity to protect your privacy and security.

In compliance with GDPR regulations, Moneta commits to resolve complaints about our collection or use of your personal information. You have a right to lodge a complaint with a competent supervisory authority situated in a member state of your habitual residence, place of work, or place of alleged infringement. You can find the relevant supervisory authority name and contact details here for individuals located in the EEA, here for individuals located in the United Kingdom and here for individuals located in Switzerland

.Additional Rights of California Users
‍The California Consumer Privacy Act (CCPA) provides certain California residents with the additional rights listed below. The rights below apply in the event that we process your information as a business, on our own behalf. In the event that we process your information on behalf of a business customer, we will either process your request or direct you to the business customer directly to make your access, portability or deletion request.

The CCPA temporarily excludes from these rights certain personal information in business-to-business communications or transactions as well as information about our employees, job applicants, contractors, controlling owners, directors, officers and medical staff (if any) in their capacities as such individuals at Moneta.

Right to Access.
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you,
- The categories of sources for the personal information we collected about you,
- Our business or commercial purpose for collecting that personal information,
- The categories of third parties with whom we share that personal information, and
- The specific pieces of personal information we collected about you (which allows you to exercise your data portability right as well).

Data Portability Right.
You have the right request that we provide you with access to the information above (Right to Access) in a readily usable format that allows you to transmit (i.e., port) the information to another entity without hindrance. If you make a request under your right to request access, you will receive access to your information in a readily usable format.

Right to Delete.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies. You must contact the applicable business customers directly to delete your information that they have in their systems.

We may deny your deletion request or not delete some of your personal information, if retaining the information is necessary for us or our service provider(s) to:
1.    Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2.    Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3.    Debug products to identify and repair errors that impair existing intended functionality.
4.    Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5.    Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6.    Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7.    Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8.    Comply with a legal obligation.
9.    Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We may also limit our deletion to the extent permitted by applicable law.

Exercising Your Rights.
To exercise your rights, please contact us as follows:
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Email us at privacy@moneta.vc and provide the following information: full name and email address associated with your use of our Service, and your specific request (e.g., right to access, right to portability, or right to delete).

We will attempt to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Non-Discrimination
‍We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services, or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.