Privacy

 

Interactive Venture Partners LLC (“Interactive Venture Partners”, “IVP”, “we”, “our” or “us”) has adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about you is an important responsibility. That is why we have developed policies and practices designed to protect the privacy of your personal information. We also know that you expect us to serve you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. By contracting with IVP or inquiring about any of our services, you have consented to the collection and use of some of your personal information in accordance with this privacy policy. We encourage you to read this privacy policy carefully.

This policy is based on the privacy and data protection principles common to the countries where we have offices and is intended to summarize our data protection practices generally and to advise our prospective partners website visitors and other third parties about the privacy policies that may be applicable to them.

This policy outlines the types of information we collect about you and how we use and safeguard that information. If you have any questions or concerns regarding this statement, you should contact us by email at info@interactivevp.com.

What Personal Information We Collect

As a general principle, you will provide us with your personal information entirely voluntarily. While there are usually no detrimental effects for you if you choose not to consent or to provide personal information, we will not be able to take certain actions you request us to without some of your personal information. For instance, personal information is required to initiate an inquiry about us. In these cases, it will unfortunately not be possible for us to provide you with what you request without the relevant personal information and we will notify you accordingly.

In order to engage with you and to comply with applicable legal obligations and regulatory requirements, IVP collects certain personal, nonpublic information from you (“Personal Information”).

This includes information collected from the following sources:

• Information acquired from communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, financial advisers, etc.);
• Information that you provide through the Contact Us portion of our website;
• Information collected from other legitimate sources (such as our affiliated companies, public sources or social networks).

We do not collect or process Personal Information related to your racial or ethnic origins, political opinions, religious or philosophical beliefs, genetic data, biometric data, or data concerning your health, your sex life or orientation.

How We Use Your Personal Information

We will collect and use your Personal Information as necessary to perform a range of activities. A few examples of these activities include:

• Taking steps at your request prior to engaging with us;
• Pursuing legitimate interests, in particular to carry out, monitor and analyze our business or website operations;
• Dealing with any requests or inquiries you may have in connection with our business;
• Sending you communications related to our relationship with you;
• Contacting you regarding financial developments that may be of interest to you;
• Complying with any applicable laws or regulations in any country; and
• Accomplishing any purpose related and/or ancillary to any of the above or any other purpose for which your Personal Information was provided to us.

How We Share Your Personal Information

We do not disclose any non-public Personal Information we collect about you to anyone except:

• To persons assessing our compliance with industry standards (e.g. professional licensing authorities, etc.); or
• To our attorneys, accountants, auditors, regulators or as otherwise required by government agencies and other third parties by law and where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process; and

Otherwise, we will only disclose your Personal Information when you direct us or give us permission, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.

How We Protect Your Personal Information

It has always been the policy of IVP to exercise the utmost discretion regarding the information that is entrusted to us. IVP maintains reasonable and appropriate, although not infallible, security precautions.

We safeguard the confidentiality of your Personal Information in a number of ways. For example:

• We never trade, sell or share your information with any unrelated parties except as necessary or appropriate to conduct IVP business activities, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party, or to further your interests, or as permitted or required by law or as authorized or directed by you.
• We maintain strict employment policies that prohibit employees who have access to your Personal Information from using or disclosing such information except for business purposes.
• We take substantial precautions to safeguard your Personal Information, and maintain physical, electronic and procedural safeguards that comply with applicable U.S. federal or state (or other applicable) standards to protect your non-public personal information.
• Our website https://www.interactivevp.com uses secure socket layer technology (SSL) so that information displayed and submitted by you is always encrypted. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
• No Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error-free; therefore, we cannot ensure or warrant the security of any information you transmit to us.

How Long We Maintain Your Personal Information

We will retain your Personal Information for as long as we find it necessary to fulfill the purpose for which the information was collected. We will generally retain your Personal Information in an identifiable form as long as necessary to meet legal, regulatory and business requirements. When the Personal Information that we have collected is no longer required, we will either delete it in a secure manner or anonymize it by removing all Personal Information associated with our records.

We will not retain Personal Information for longer than it is necessary. Notwithstanding this provision, we may retain this Personal Data past standard retention periods where such retention is necessary for compliance with a legal obligation to which we are subject (e.g., in connection with litigation, investigations and proceedings) or in order to protect your vital interests or the vital interests of another natural person.

Other Important Information

Changes to Our Privacy Policy or Relationship with You

We may need to update this Privacy Policy from time to time. The latest version of this policy will always be found on the Privacy Policy page of our website at https://www.interactivevp.com and in the footer section of our website. Should we make any changes to this Privacy Policy that may significantly alter our privacy practices, we will provide you with notice through our website. Changes to the Privacy Policy will take effect as soon as posted on our website.

Data Transfer

We will comply with the General Data Protection Regulation (“GDPR”) requirements providing adequate protection for the transfer of Personal Information from the European Union to the United States. We will also require our agents, consultants and sub-contractors and others who are outside of the European Economic Area or the United States and to whom we transfer your Personal Information to ensure a similar level of data protection. When doing so we will comply with applicable data protection requirements and take appropriate safeguards to ensure the security and integrity of your Personal Information.

Other Terms and Conditions

There may be other specific terms and conditions in our agreement with you that govern the collection, use and disclosure of your Personal Information.

Contact Us

This website is owned and operated by Interactive Venture Partners LLC. Interactive Venture Partners LLC is a limited liability company registered in the Delaware, US. Its principal place of business is at One Pickwick Plaza, Greenwich, CT 06830. Interactive Venture Partners LLC is an exempt reporting adviser with the U.S. Securities and Exchange Commission. You may contact us by e-mail at info@interactivevp.com. You may also find our contact information on this webpage: https://www.interactivevp.com.

If you have any questions relating to our use of your Personal Information please contact us at info@interactivevp.com.

Notice of Rights under the California Consumer Privacy Act

The California Consumer Privacy Act of 2018 (“CCPA”) gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. This landmark law secures new privacy rights for California consumers, including:

• The right to know about the personal information a business collects about them and how it is used and shared;
• The right to delete personal information collected from them (with some exceptions);
• The right to opt-out of the sale of their personal information; and
• The right to non-discrimination for exercising their CCPA rights.

The CCPA is not applicable to IVP as we do not meet one or more of the Act’s regulatory thresholds. We never trade, sell or share your information with any unrelated parties except as necessary or appropriate to conduct IVP regulated and business activities, subject to appropriate confidentiality, privacy and information security commitments provided by the receiving party, or to further your interests, or as permitted or required by law or as authorized or directed by you. Nevertheless, California residents can request information related to Personal Information we have collected about them and/or request deletion of their Personal Information by referring to “How Long We Maintain Your Personal Information” and/or contacting us.

Notice of Rights under the European Union’s General Data Protection Regulation

IVP is subject to the requirements of the European Union General Data Protection Regulation (“GDPR”). For purposes of GDPR, Personal Information is any information relating to an identified or identifiable natural person. This policy applies when we are acting as a data controller with respect to the Personal Information of website visitors, i.e., where we determine the purposes and means of processing that Personal Information. If we intend to further process your Personal Information for a purpose other than that for which it was initially collected, we will provide you with information on that other purpose before we use it. We procure consent from website visitors and other recipients of our emails to process their Personal Information.

If you are a natural person and we process your Personal Information under this policy or through consent, GDPR grants you the following rights with respect to your Personal Information:

1. The right to be informed. You have the right to be informed about IVP’s collection and use of your Personal Information, including information about our purposes for processing your Personal Information, our retention period for that information and who this information is shared with.
2. The right of access. You have the right to request a copy of the Personal Information that IVP collects and processes for you. We may request appropriate evidence of your identity before responding to such a request. We will normally respond within a period of one month from the date we receive the request. If we process a large amount of your data, we may respond within three months of the date we receive your request but will email you within one month to let you know whether that is the case. If a request is manifestly unfounded or excessive, we will notify you whether that is the case and whether or not we will respond to it. The first copy of your Personal Information will be provided free of charge, but additional copies may be subject to a reasonable fee.
3. The right of rectification. You have the right to request that IVP correct your Personal Information if inaccurate, incomplete or out of date.
4. The right to erasure. In certain circumstances, you have the right to request deletion of your Personal Information without undue delay. For instance, you have the right to request that your Personal Information be deleted when it is no longer necessary for IVP to retain such data for the purposes of which that information is processed. You may withdraw consent to consent-based processing. There may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it, e.g., when we need to comply with a legal obligation or need to establish, exercise or defend legal claims.
5. The right to restrict processing. You have the right to restrict the processing of your Personal Information or withdraw your consent to Personal Information processing at any time. For instance, you may request to restrict the processing of your Personal Information when: you contest the accuracy of your Personal Information; processing is unlawful but you are opposed to deletion of Personal Information; we no longer need the Personal Information for the purpose of processing, but you may need it for the establishment, exercise or defense of legal claims. When restricted on this basis, we may continue to store your Personal Information but only: with your consent, for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest.
6. The right to data portability. You have the right to request that we provide you with your Personal Information and, if possible, provide this information directly (in a portable format) to another service provider when the processing is based on consent or contract.
7. The right to object to processing. You have the right to object to the processing or request a restriction of further processing of your Personal Information by IVP based on legitimate interest and/or direct marketing. If you make such an objection, we will cease to process your Personal Information unless we can demonstrate compelling legitimate reasons for processing which override your interests, rights and freedoms or the processing is for the establishment, exercise or defense of legal claims.
8. The right to lodge a complaint with a supervisory authority if you believe that our processing infringes data protection laws. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
9. The right to withdraw consent to the processing of Personal Information, if that is the basis for processing. Withdrawal of your consent does not affect the lawfulness of processing before withdrawal. Also, in certain circumstances it may be lawful for us to continue processing your Personal Information without your consent if we have another legitimate reason for doing so.
10. You have the right to object to our processing of your Personal Information for direct marketing purposes. If you do, we will cease to process your Personal Information for this purpose.

 

To exercise any of the above rights, you may send an email to info@interactivevp.com. We may request that you prove your identity by providing us a copy of a valid means of identification in order for us to comply with our security obligations and prevent unauthorized disclosure of data.

We have attempted to summarize above the rights granted by GDPR. Please note that some of these rights are complex and not all of the details could be included in this summary. You should read the relevant laws and guidance for a full explanation of these rights.

We will consider any requests or complaints that we receive and provide you with a response in a timely manner. If you are not satisfied with our response, you make take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.