Privacy Policy

This Privacy Policy describes the privacy practices of e.ventures US Master Manager, LLC and our subsidiaries and affiliates (collectively "Headline," "we", “us” or "our") and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our websites and mobile applications (collectively, the “Service”), as well as through social media, our marketing activities, our live events, and other activities described in this Privacy Policy. Our use of personal information that we handle on behalf of our business customers in our capacity as their service provider is restricted by our agreements with those customers and is not covered by this Privacy Policy. You can download a printable copy of this Privacy Policy here.

# Index

1. Personal information we collect
2. How we use your personal information
3. How we share your personal information
4. Your choices
5. Notice to end users
6. Other sites and services
7. Security
8. International data transfer
9. Children
10. Changes to this Privacy Policy
11. How to contact us
12. Information for California residents
13. Notice to European users

# Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise, includes:

• Contact data, such as your first and last name, email address, billing and mailing addresses, phone number, professional title, and organizational affiliation.
• Account data, such as the username and password associated with an account on the Service, account preferences, and any other registration data associated with a Service account.
• Business data such as profit and loss information, number of customers and transactions, and capital information that you ingest into the Service for analysis.
• Communications that we exchange with you, including when you contact us with questions or feedback, through social media, or otherwise.
• Financial data, such as your income, economic or financial status, investment holdings and preferences, account balances and contributions, ability to invest, and information that you provide in subscription agreements or investor questionnaires.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Administrators, where your Service account is created and administered for you by an administrator.
• Public sources, such as social media platforms, publications, and news sites. Business partners, such as Stripe or Shopify, if you associate your account with the Service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice.

# How we use your personal information

We use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We use your personal information to:

• provide, operate and improve the Service and our business;
• conduct Know Your Customer checks, background checks and other screens permitted by law;
• establish and maintain your user profile on the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you or your employer about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We may send you Headline-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to: comply with

• applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from
• government authorities; protect our, your or others’ rights, privacy, safety or property (including by
• making and defending legal claims); audit our internal processes for compliance with legal and
• contractual requirements and internal policies; enforce the terms and conditions that govern the
• Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or
• illegal activity, including cyberattacks and identity theft.

# How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, print and mail fulfillment, email delivery, marketing, website analytics, and providers of background and other screening services).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Headline or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our Service, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

# Your choices

You have the following choices with respect to your personal information. Where the Services are administered for you by an administrator (see Notice to End Users below), you may need to contact your administrator to assist with your requests first.

Access or update your information. If you have registered for a Service account with us, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may continue to receive service-related and other non-marketing emails.

Cookies. For information about cookies and similar technologies employed by the Service and how to control them, see our Cookie Notice.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Third party platforms. If you choose to connect to the Service through your social media account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

# Notice to end users

Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization's policies. We are not responsible for the privacy or security practices of an administrator's organization, which may be different than this policy.

Administrators are able to require you to reset your account password; restrict, suspend or terminate your access to the Services; access and retain information in and about your account; change the email address associated with your account; change your information, including profile information; and restrict your ability to edit, restrict, modify or delete information.

# Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

# Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

# International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

# Children

The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Service from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

# Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

# How to contact us

• Email: privacy@headline.com
• Mail: Headline, 101 Montgomery Street, San Francisco, CA 94129, United States
• Phone: 888-310-0110

# Information for California residents

Scope. This section applies only to California residents. It describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA such as personal information collected, processed, or disclosed pursuant to the Gramm-Leach-Bliley Act.

In some cases we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected the Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share the Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Opt-out of sales. If we sell your Personal Information, you can opt-out of those sales.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion using this form, or via email to privacy@headline.com.

We have not sold your Personal Information in the preceding 12 months.

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to provide government identification, give a declaration as to your identity under penalty of perjury and/or provide additional information. Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request.

Authorized agents are required by California law to implement and maintain reasonable security procedures and practices to protect their clients’ information.

Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.