Decile Hub Privacy Policy

If you have any questions or concerns about our Privacy Policy or our data practices, please contact us at the following address:

Decile Group Privacy Office
548 Market Street PMB 64705
San Francisco, California 94104-5401
Email: privacy@decilegroup.com

Principles

Our mission is to help build and grow enduring venture capital firms, and we take the privacy of our users seriously. Our Privacy Policy is based on the following principles:

You control your data access - You control access to your workspace, including granting and revoking user access to specific types of data.

Your data is not for sale - Our business model does not involve selling our customers’ personal data.

We seek double opt in - We pursue a double opt in strategy to ensure that all parties explicitly consent to offerings and services provided.

We publicly share only anonymous data - We track anonymous data from users, such as aggregate investment data, to improve our offerings and for market insights.

We follow the Mensarius Oath - We abide by the Mensarius Oath and conduct periodic audits to ensure our compliance with these principles.

Privacy Policy

We are committed to protecting your privacy. This Privacy Policy describes our practices regarding the Personal Data we collect from users of our Sites and the Materials that are made available or enabled via the Sites. Capitalized terms have the meanings given such terms in the Definitions section at the end of this Privacy Policy.

General Use of Your Data

In general, we use your Personal Data to support the services that we provide to you to manage and grow your firm and support the community of investors in venture capital. We use your Personal Data to (i) communicate with you for support, (ii) improve our services, Sites and Materials for your purposes, (iii) provide you with information on our products and services, and (iv) prevent fraudulent activity and otherwise comply with law. Unless you provide permission, your Personal Data will remain confidential unless required by law.

Types of Data We Collect

When you use our Sites and access our Materials we may collect certain information from you. This includes the information described below.

Information You Provide to Us. We may collect Personal Data from you. If you provide us feedback, post an event or contact us via e-mail, we may collect your name and e-mail address, as well as other content you provide to us.

Information Collected by Technology. Our servers may collect information from you, including your browser type, operating system, IP address, domain name, and time stamp of your visit. We gather this information automatically and may store it in log files. We use this information to analyze trends, administer the Sites, track users’ movements around the Sites, and to gather demographic information about our user base. Some of the information may be collected so that when you visit the Sites, it will recognize you, and the information could then be used to provide information appropriate to your interests.

Cookies. We use cookies to collect information. “Cookies” are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a website or mobile application. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognizes those cookies. We use cookies to enhance the online experience of our visitors and to better understand how our site is used. Our Sites use the following types of cookies:

Cookies necessary for essential purposes: These cookies are essential to provide you with services and features available through our Sites.

Analytics Cookies: These cookies are used to collect information about how visitors use our Sites. The information gathered does not identify any individual visitor and is aggregated. We use this information to help operate our Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Sites.

Performance Cookies: These cookies collect information about how visitors use the Sites, so that we can analyze traffic and understand how our Site is performing.

Functionality Cookies: These cookies allow our site to remember choices you make and provide enhanced, more personal features.

Social Media Cookies: These cookies are used when you share information using a social media sharing button or “like” button on our sites or you link your account or engage with our content on or through a social networking site. This information may be linked to our marketing activities.

Pixel Tags. We may use “Pixel Tags”, also known as clear Gifs, Web beacons, or Web bugs. Pixel Tags are used to track online movements of Web users. Pixel Tags allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened which helps us eliminate unwanted messages.

Google Analytics. We use Google Analytics to help analyze how users use the Sites. Google Analytics uses Cookies to collect information. We use the information we get from Google Analytics only to improve the Sites. Google Analytics collects only the IP address assigned to you on the date you visit the Sites, rather than any personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can avoid the use of Google Analytics relating to your use of our site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Anonymous Data. We may create Anonymous Data from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you or any other party. We may use this Anonymous Data to analyze usage patterns so that we can improve the Sites, including use for training AI models. We reserve the right to use Anonymous Data and disclose Anonymous Data to third parties in our discretion provided that you cannot be identified by such Anonymous Data. We use such data to provide reports and insights for the benefit of the community.

No Advertisements. We do not use third parties to serve ads on the Site or collect personally identifiable information about your online activities.

Members of Decile Hub

If you become a registered member of Decile Hub, we may collect additional Personal Data from you, as well as personal information associated with your investors and other contacts you enter into Decile Hub (“End Users”), that may include the types of information listed below.

Category	Details
Identity Data	Names, social security numbers, forms of identification, personal information on applications and identification forms.
Contact Data	Addresses, email address and telephone numbers.
Professional Background Data	Educational and professional history.
Online Data	Links to your public account pages at social media and personal websites.
Financial Data	Your bank account, payment card details, and financial statements.
Transaction Data	Data on your transactions on Decile Hub.
Investment Data	Information about your investment objectives, investment experience, prior investments, and other information you provide.
Content Data	Any content you post to Decile Hub.
Marketing Data	Your preferences in receiving marketing from us and our third parties and your communication preferences.
Behavioral Data	Information relating to your behavior and interests based on your online activity.

Personal Data from Third Party Sources. In addition to the Personal Data that we collect directly from you, we may also collect certain of your Personal Data from third party sources, some of which may not be publicly available. Examples of these sources are broken down in the table below.

Third party data source	Categories
Social Media Sites	Identity Data Contact Data Online Presence Data
Our Affiliates	Identity Data Contact Data Marketing Data Behavioral Data Investment Data Transaction Data Financial Data Content Data
Our Fund Administration Partners	Identity Data Contact Data Investment Data Transaction Data Financial Data
Analytics Providers	Behavioral Data Technical Data
Identity Verification and Compliance Service Providers	Identity Data Contact Data

Third Party Service Providers

Examples of our integration with third party service providers:

Google Gmail. If you sign up for Decile Hub with a Gmail address and upon your authorization, Decile Hub will automatically sync with your Gmail account. This means that Decile Hub will access your Gmail contacts, emails, calendar, distribution lists, subject lines and URLs of tracked links from your email, if you use the email tracking functionality. In addition, you can use Decile Hub to read, modify, create, and send emails from your Gmail account. Decile Hub will store replies, outgoing mail, email headers, subject line, distribution lists, aliases, time sent, and email bodies (all such data, "Google User Data"). We will use Google User Data only to provide or improve user-facing features of Decile Hub. We will not allow humans to read your Google User Data unless we have first obtained your affirmative agreement for specific messages; it is necessary for security purposes; it is necessary to comply with applicable law; or our use is limited to internal operations and the data (including derivations) have been aggregated and de-identified. Our use and transfer to any other application of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Google Drive. You have the option to connect your Google Drive account to Decile Hub. If you choose to do so, you will be able to see your files, upload and download your files, and store file contents and titles on Decile Hub. Decile Hub uses these permissions to associate files with records stored on our platform and allow users to share them with clients and other users.

Data Storage. Documents that are uploaded to the Sites for sharing are stored at a third party data-storage service. All uploads and downloads are transmitted through the web between users and the data storage service using the same encryption techniques as those that are used with Personal Data. Uploaded documents are neither stored redundantly, nor backed up. We recommend that users keep back-up copies of their documents.

Third Party Websites

The Sites may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Changing Your Data

You have several options to change your data on our Sites.

Deletion Requests. Personal Data submitted by you for document generation and other purposes will be retained for such period as may be required to fulfill the purposes set out in this Privacy Policy, or such other period as may be required by law. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required by law to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

Email Communications. We may periodically send you free newsletters and promotional e-mails if you have indicated that you would like us to do so. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). Despite your indicated e-mail preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or Privacy Policy.

Do Not Track Browser Setting. We do not currently respond to “do not track” signals from web browsers.

Certain Disclosures

Mandated Disclosures. Regardless of any choices you make regarding your Personal Data, we may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Decile; (c) to protect or defend the rights or property of Decile or users of the Sites; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

Corporate Restructuring. We may share some or all of your Personal Data with entities within our group of companies. We may also share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.

Security

We follow generally accepted industry standards and maintain reasonable safeguards designed to secure the information in our possession, and take steps to ensure only those at Decile with a legitimate business need to access your personal information are permitted to do so. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information.

Children under 16

The Sites and the services available on the Sites are not intended for children below 16 and we do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under the age of 16, please do not submit any personal information through the Sites.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.

Jurisdictions

Decile may collect or otherwise process information deemed to be sensitive under global laws and regulations (aka; “special category data”). This information may include:

• Information used to identify, verify or authenticate identities, including government issued identifiers, official government documentation, or biometric information.
• Information associated with financial transactions or accounts, including banking account information, historical transactions, payment card, wallet or other financial instruments used to transact.
• Background and reputation information including citizenship, race or ethnicity.

Decile will not use any sensitive personal information for commercial purposes other than to directly provide its product and services. If you would like to control our use of any sensitive personal Information please contact us at privacy@decilegroup.com. If you are an End User through one of our Members, please contact that Member directly.

U.S. State-Specific Notice

Certain U.S. states have enacted comprehensive privacy laws that create additional privacy obligations for businesses and provide their residents with additional privacy rights.

Additional Privacy Rights:

In addition to the rights granted above, if you are a resident of a state with enhanced privacy rights, you may also have the right to:

• Opt out of the “sale” or “sharing” of your personal information for the purpose of cross-context behavioral or targeted advertising.
• Opt out of profiling or automated decision making. Decile currently does not engage in any activities that would require enabling such a choice at this time.
• Sensitive Personal Information. Decile enables you to request deletion or our use of any personal information deemed sensitive under state laws by contacting us at privacy@decilegroup.com or through your Decile account manager.

Decile does not sell any personal information associated with our Decile Services.

If you reside in the UK or the European Economic Area (“EEA“)

The European Economic Area (“EEA”) and the United Kingdom (“UK”) have each enacted privacy laws. The European Union’s (“EU”) and the UK’s General Data Protection Regulation (collectively, the “GDPR”) create additional privacy obligations for ‘Controllers’ of personal data and provide EU and UK residents with additional privacy rights.

Legal Basis:

Under the GDPR, we process personal data under the following legal bases.

Controller Designation:

Under the GDPR, we are designated as a “Controller” of our client personal data. However, in receipt of our clients’ End User personal data, we operate as a “Processor”. A list of our subprocessors is available to our Clients on-demand.

Cross-Border Data Transfers:

Decile may store personal data in the United States. As such, if you are a resident of the EEA, UK, or Switzerland, we may transfer to, and store the data we collect about you, to countries other than the country in which the data was originally collected, including the United States. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA, UK, and Switzerland.

For our business services, we may rely on the Standard Contractual Clauses (“SCCs”) adopted by the European Commission for the transfer of personal data to countries that have not received an applicable adequacy decision, as well as the UK’s “International Data Transfer Addendum” to the SCCs.

Without prejudice to your privacy choices referenced above, we may be required to disclose personal information in response to lawful requests by public authorities, including those made for national security or law enforcement purposes.

For more information on cross-border transfers of your Personal Data or the appropriate safeguards in place, please contact us at privacy@decilegroup.com.

Additional Rights for UK or European Economic Area Residents:

In addition to the rights granted above, if you are a UK or EEA resident, the GDPR grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you reside in Canada or Singapore

If you reside in Canada or Singapore, you may request to access and/or correct your Personal Data currently in our possession by writing to us.

You agree that your Personal Data may be transferred to and processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. We may transfer your Personal Data to a country or territory outside Canada or Singapore in accordance with requirements prescribed under the Canada Personal Information Protection and Electronic Documents Act (“PIPEDA”), Quebec Bill C-27, or Singapore Personal Data Protection Act (“PDPA“) to ensure that we provide a standard of protection to Personal Data so transferred that is comparable to the protection under the PDPA. By providing your Personal Data, you consent to such transfer. We will take commercially reasonable efforts to ensure that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that the purpose for which your Personal Data was collected is no longer being served by the retention of such Personal Data.

Definitions

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data, and for registered members of Decile Hub may include additional data as further described in the section titled Members of Decile Hub.

“Anonymous Data” means data that is not associated with or linked to your Personal Data. Anonymous Data does not, by itself, permit the identification of individual persons.

“Sites” means our websites and the services offered on those Sites which includes access and information available on our channels such as LinkedIn, Twitter and Slack.

“Materials” refers to the information, reports, data, templates, agreements and other materials on the Sites. You automatically agree to this Privacy Policy simply by using or logging into the Sites or using the Materials.