Privacy policy and disclosures

Privacy policy

Ulu Ventures Management Company, LLC, together with its affiliates and funds (“Ulu”, “us”, “our” or “we”), have created this Privacy Policy to explain how we collect, use and share information we obtain through our organization, website and its various pages located at www.uluventures.com (the “Sites”) and other online services that we offer and control (together, the “Internet Services”).

Due to the global nature of the Internet, information about you that we collect or that you submit may be transferred to, processed in, and/or held in countries (including the United States) other than the one in which you reside. By accessing the Sites, you acknowledge use of your information in accordance with this Privacy Policy and agree to the terms of this Privacy Policy.

This Privacy Policy was updated as of November 18, 2024.

Information We Collect and Use

Information You Submit. To obtain access to and browse the Sites and/or to receive certain Internet Services, you may be required to log in and provide certain information about yourself (for example, your username, name and password) , and we may collect or receive other information from time to time about you in connection with the Sites and/or Internet Services  (“Personal Data”). We may use Personal Data to fulfill your requests for Internet Services, as well as other products and services (together, the “Services”), to monitor and improve our Services, and to contact you from time to time about us and the Services. As of the date of this Privacy Policy, you are not required to log in to the Sites.

Information We Collect Automatically. We automatically collect, or you may leave by nature of your browsing, certain information related to your access to and activity on the Site to help us understand your interests and/or how you use the Internet Services (which we will refer to in this Privacy Policy collectively as “Usage Data”). For example, each time you visit the Sites we may automatically collect your IP address, browser and device type, access time, the webpage from which you came, the webpage(s) that you access during your visit, and similar information. Although it is generally not our intent to do so, we may combine Usage Data with Personal Data in a manner that enables us to trace Usage Data to an individual user. Some web browsers may have “do not track” settings. The Sites do not currently honor “do not track” settings unless otherwise required by law.

We also may use first-party and third-party cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive) and other tracking technologies to keep track of your use of the Internet Services, to validate your identity, to remember your password and preferences, to tailor the Internet Services to your account and to meet your interests, and to improve the quality and security of the Internet Services. Although it is generally not our intent to do so, we may use these technologies to track you across different websites, devices, and the Internet Services. Generally, you can set your browser not to accept cookies or other tracking technologies, or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser to reject cookies, certain Internet Services may not function properly.

Other Uses. We may also use Personal Data that you submit or we collect or receive about you to (i) perform analysis about our business, the Services and/or your use of the Services; (ii)  enforce our legal rights, terms and conditions, and other agreements; (iii) manage our business; (iv) engage in security and compliance activities; and (v) perform functions as requested by you or otherwise described to you at the time of collection. In addition, we will use the information you submit in the Intake Form under https://uluventures.com/become-an-ulupreneur/ (or successor pages or URLs on our Sites that present the Ulu Intake Form) to evaluate you and your company for a potential investment. Your submission of your information through the Intake Form grants us the right to use internally any data and materials submitted for the purpose of investment consideration or other internal business purposes; we will not otherwise share those materials externally without your permission.

Some Personal Data may be collected by social networking sites, social media companies, event organizers, our service providers, or other organizations. If you interact with some of these organizations, such as social media companies, particularly where you have an account with them, they may collect additional information separate from Ulu.

Automated Decisions. We will not use Personal Data to formulate a decision based solely on automated processing which produces legal effects or similarly significantly impacts the person.

Other Information. Ulu may collect, use and share other information from your use of the Internet Services, or other information available to Ulu, provided such information does not individually identify you or otherwise qualify as “Personal Data” (or similar concept) under an applicable law, including but not limited to Ulu de-identifying Personal Data to create such information. Ulu shall have the right to retain records of such data including, but not limited to, usage, activity logs, and click-throughs. Ulu may disclose such data, whether in the form collected or a derivative form, to others provided it is presented in an aggregate and/or deidentified form.

Where we have de-identified Personal Data covered by a privacy law, we will use such data only in de-identified form and not attempt to reidentify the data, unless permitted by the applicable law.

Ulu in the course of its business may collect, use and disclose other information, separate from information in connection with the Sites, such as information about customer prospects, employees and employment candidates, vendor employees (i.e., their business contact information), and other information as part of operating its business. Additional information about our use of this Personal Data and other information, to the extent not already covered herein, may be obtained by utilizing the contact information below.

 

Our Information Sharing Practices

We do not sell, and have never sold, Personal Data.

We employ other companies and individuals to perform functions on our behalf, such as for analyzing data and providing certain of the Internet Services. These third-party service providers may have access to Personal Data needed to perform their functions, but we require that they not use Personal Data for other purposes. Personal Data is not shared with any unaffiliated third parties for their marketing purposes.

We may disclose Personal Data to others (1) in response to subpoenas, court orders, regulatory requests or legal process, or to establish, protect or exercise our legal rights and interests or defend against legal claims; (2) if we believe it is necessary in order to investigate, prevent or take action regarding inappropriate or illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent, or take action regarding inappropriate use of the Internet Services; (4) where “others” may include our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); and (5) as part of a corporate transaction with a successor or affiliate or in connection with any acquisition, merger or sale of assets.

Lawful Basis of Processing

Certain jurisdictions require a lawful basis for processing of Personal Data, and we will only collect and process your Personal Data there where we have lawful basis. Our lawful basis include consent (where you have given it), where processing is necessary for the performance of a contract or other requested transaction with you, and for the purposes of our legitimate interests or the legitimate interests of our third parties, provided that such interest does not outweigh your rights and freedoms. Examples of legitimate interest include but are not limited to: (i) complying with applicable law, (ii) protecting against security or other threats, (iii) administration of our business interests, including improvements and enhancements of our business, and (iv) customer relationship issues.

Data Retention

We may choose to retain Personal Data for as long as necessary for the fulfillment of the purposes described herein, unless otherwise restricted by an applicable law.

Whenever applicable, Ulu identifies the purposes for which the information is being collected before or at the time of collection. The collection of your Personal Data will be limited to that which is needed for the purposes identified by Ulu. Unless you consent, or we are required or permitted by law, we will only use the Personal Data for the purposes for which it was collected or another purpose described to you at that time or that is described in this Privacy Policy. If Ulu will be processing your Personal Data for another purpose later on, Ulu will use commercially reasonable efforts to seek your further legal permission or consent, except where the other purpose is compatible with the original purpose or is otherwise permitted by applicable law.

We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, whether individually or as a member of a larger group.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory and tax, accounting or other requirements.

In some circumstances you can ask us to delete your Personal Data (see Your Rights below).

In some circumstances we will de-identify and/or aggregate your Personal Data (so that it can no longer be readily associated with you) for research, statistical or other permitted purposes, in which case we may use this information indefinitely without further notice to you.

Your Rights

We have controls in place designed to ensure that the information we have is relevant, accurate, and appropriate for the purposes used. If you believe that any data about you is inaccurate, you can let us know by contacting us at privacy@uluventures.com. Please note that any Personal Data that we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain information, you may not be able to use our services in the future without re-submitting such information. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law or regulation.

Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their Personal Data; (ii) restrict or object to the processing of their Personal Data; and (iii) obtain a copy of their Personal Data in a portable format. Individuals may also have the right to lodge a complaint about the processing of Personal Data with a data protection authority. The rights described herein are not absolute and may not be applicable to you. We reserve all of our rights available to us at law in this regard. If you wish to exercise any of these rights please email privacy@uluventures.com.

If you are an individual in the EU / EEA, you have the right to make a complaint to the relevant Supervisory Authority. A list of EU / EEA Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  If you are in the UK, you have a right to make a complaint to the UK Information Commissioner’s Office. You can visit their website at www.ico.org.uk. We encourage you to contact us first at privacy@uluventures.com so that we can attempt to address your concerns.

As of the date of this Privacy Policy, we are not subject to the California Consumer Privacy Act (“CCPA”). However, if we are at some future point considered a covered entity subject to the CCPA or other similar comprehensive state privacy laws in the United States, those laws may, if and when applicable to the Sites and the Internet Services, provide other rights, including but not limited to, as applicable: (i)  the ability to access, correct/update, erase, and receive in a portable format, Personal Data; (ii) opt-out of the sale of Personal Data and sharing of Personal Data for cross-contextual behavioral advertising; (iii) restrict certain processing; and (iv) request additional information concerning Ulu’s privacy practices in connection with your Personal Data, among other rights.

Under the CCPA and in certain other state privacy laws, covered individuals may have the right to request certain information from a company subject to the CCPA and similar laws about that business’s collection and use of the requesting individual’s Personal Data over the previous 12 months, including: (i) categories of Personal Data that have been collected about you; (ii) specific pieces of Personal Data that have been collected about you; (iii) categories of sources from which that Personal Data was collected; (iv) business or commercial purpose for collecting your Personal Data; and (v) categories of third parties with whom your Personal Data has been shared.

The CCPA also prohibits covered businesses from discriminating against you for exercising applicable CCPA rights.

Under California Civil law, Californians are also entitled to request information relating to whether a business has disclosed Personal Data to any third parties for the third parties’ direct marketing purposes. Californians who wish to request further information about our compliance with this statute or who have questions, more generally, about our Privacy Policy and our privacy commitments and our Sites can contact us at privacy@uluventures.com.

Please note that if you wish to exercise various privacy rights, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose Personal Data is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request, unless we are otherwise required by law to retain the information or need to retain it for legitimate security purposes, in which case we will retain it only for as long as necessary to meet these purposes. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written verifiable proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law.

If you live in a different country, state or other jurisdiction that provides for additional rights or disclosures regarding your Personal Data, and you wish to exercise those rights or receive those disclosures, please contact us at privacy@uluventures.com or by using the contact information below.

 

SEC Regulations S-P, S-AM and the Gramm-Leach-Bliley Act

Some regulators such as the Securities and Exchange Commission, the U.K. Information Commissioner and the Federal Trade Commission have adopted rules that require financial institutions, like Ulu, to provide privacy policy notices to their clients. If you are a natural person who invests with us, that notice will govern how we use your Personal Data.

Security

We have implemented measures to help protect Personal Data from loss, misuse or unauthorized access or disclosure. While we strive to protect Personal Data, we cannot guarantee its security.

Links

The Sites may contain links to other websites. We are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information to such websites.

Children’s Privacy

We do not knowingly collect any information from anyone who we know to be under the age of 18. If you are under the age of 18, you should use this website only with the involvement of a parent or guardian and should not submit any Personal Data separately to us. If we discover that a person under the age of 18 has provided us with any Personal Data, we will use commercially reasonable efforts to delete such person’s Personal Data from all systems.

Changes

We may update this Privacy Policy from time to time. If under any such update we make any material change to the way in which we treat your User Information, we will inform you of such change via e-mail or by posting a notice on relevant areas of the Sites. Any updated version of this Privacy Policy will be effective as of the date set forth therein. By continuing to use Internet Services, you expressly agree to the terms of the Privacy Policy.

Questions

If you have any questions about this Privacy Policy, please feel free to contact us by e-mail at privacy@uluventures.com.

Our postal address is:

Ulu Ventures
405 El Camino Real, Suite 416
Menlo Park, CA 94025

 

Our physical address is:

 Ulu Ventures
115 Everett Avenue
Palo Alto, CA 94301

Please direct written inquiries to our postal address.

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