Privacy Policy

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Effective Date: June 24, 2020

CenterHarbor Canapi Ventures Investment Advisor LLC (“Canapi” or “we”) respects your privacy. This privacy policy (“Policy”) describes how we collect, use, and share your personal information when you visit the Canapi website, https://canapi.com/, or use Canapi Connect (collectively, the “Site”). Please read this Policy carefully. By using the Site, you agree to our collection, use, and sharing of your personal information as described in this Policy.

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This Site is controlled, operated, and administered by Canapi from its offices within the United States. If you are accessing this Site from a location outside the United States, you acknowledge and consent to the collection, storage, processing, and transfer of your personal information to our facilities in the United States and to those third parties with whom we share it as described in this Policy. Please note that privacy laws in the United States may not offer the same protections as the laws of other countries.

This Policy does not apply to personal information that is protected by financial privacy laws. If you are an individual investor, please see our GLBA Notice for information about how we collect, use, protect, and disclose your personal financial information.

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Collection of Personal Information

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Through your use of the Site, we may collect personal information, which is information that identifies an individual or relates to an identifiable individual. Personal information may include, but is not limited to, your first and last name, physical address, email address, date of birth, and payment information. We collect the following types of information:

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Information Provided by You

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We collect the personal information that you provide to us. If you choose to contact us to learn more about our services, we may collect information such as your full name, telephone number, and email address. We will also collect any other information that you provide to us or through the Site, such as your questions, comments, or feedback.

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We may also collect personal information in connection with your account on Canapi Connect. This includes your contact information, information you choose to include in your profile, information you share on forums or the content of messages you send to us.

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Information Automatically Collected

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We may automatically collect the following types of information when you use the Site:

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Usage Information: We collect certain information automatically through your use of the Site, such as which pages of the Site that you access and which features you use, the frequency of access or use, what you click on while on the Site, and how you interact with others on the Site.
Device Information: We may collect information about the device you are using to access the Site, such as IP address, hardware model, operating system, application version number, browser information, connection type, and other device attributes.
Location Information: We may collect information about your location which may be inferred from your IP address.
Mobile Device Information: In addition to the Device Information listed above, when you access the Site via a browser on your mobile device, we may also collect mobile network information, such as the unique device identifier assigned to that device, mobile carrier, operating system, and other device attributes.

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Aggregate Information

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We may collect statistical or aggregated information that does not directly identify a specific person, but is derived from your personal information. For example, we may aggregate personal information to calculate the percentage of Site visitors in a particular ZIP code.

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Use and Disclosure of Personal Information

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We use the personal information that we collect in the following ways:

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To provide services that you request or fulfill our contractual obligations to you, such as completing transactions on the Site.
To provide and personalize your use of the Site, such as authenticating you when you log in and providing tailored features that personalize your experience.
To communicate with you, such as notifying you about updates to the Site or your account.
For marketing or promotional purposes, such as informing you of additional products or services that may be of interest to you.
For specific purposes for which you provide consent, such as if you consent to fill out surveys regarding services provided by us, our affiliates, or partners.
To provide customer service or technical support, such as contacting you in response to your inquiries, comments, and suggestions or when otherwise necessary.
To maintain and improve our Site or services, such as to troubleshoot or to identify trends, usage, activity patterns, and areas for improvement of the Site.

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We reserve the right to share information, including personal information, with third parties, including:

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With our service providers or independent contractors: We may share information with third parties that provide services to us in connection with our business operations, such as website and application development, hosting, maintenance, backup, storage, and payment processing services.
Within our corporate family: We may share information with our affiliates, joint ventures, or other companies under common control with us, to the extent permitted by law.
With other fund investors: We share contact information in an investor directory with other investors that have authenticated into the online system.
If there is a change in corporate structure: We may share information in connection with a proposed or actual merger, acquisition, consolidation, change of control, or sale of all or a portion of our business or property or if we undergo bankruptcy or liquidation.
To prevent harm: We may share information if we believe it is necessary in order to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.
For legal purposes: We will share information where we are legally required to do so, such as in response to court orders or legal process; to establish, protect, or exercise our legal rights; to defend against legal claims or demands; or to comply with applicable legal requirements.
For legitimate business purposes: We reserve the right to share information with third parties for our legitimate business purposes, to the extent permitted by law.
With your consent: We may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose.
Without identifying you: We may share information in a manner that does not identify you. For example, we may share anonymous, aggregate information about your use of our Site and services with our service providers.

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Protection of Personal Information

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The security of your personal information is important to us. We maintain reasonable physical, technical, and administrative security measures to protect and limit access to your personal information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially-acceptable means to protect your personal information, we cannot guarantee its absolute security.

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Use of Cookies and Other Tracking Technologies

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We may directly or through our third-party service providers collect information through “cookies” or other tracking technologies (e.g., web beacons, device identifiers, and pixels). Cookies are small strings of text sent by our Site to your browser and then stored by your browser on your device’s hard drive. Cookies help us understand how you use our Site and other linked websites so that we can personalize and improve your experience on our Site. Most web browsers automatically accept cookies, but you may change your browser settings so it won’t accept cookies.

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The Site does not respond to “Do Not Track” signals sent by Internet browsers.

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Third-Party Information Collection

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Some content or applications on the Site may be provided by third parties, including advertisers, ad networks and servers, analytics companies, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different sites and other online services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions, you should contact the responsible provider directly.

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This Site uses Google Analytics and Google Tag Manager, which are web analytics services provided by Google, Inc. (“Google”). Google Analytics uses cookies to collect information about your use of the Site, such as your IP address or other identifiers, browser information, and browsing information. This information is transmitted to Google and used for the purpose of evaluating use of the Site, compiling reports on Site activity, and providing other services relating to Site activity. Google Tag Manager is a system to manage JavaScript and HTML tags used for tracking and analytics on websites. For more information about how Google collects and uses information, visit https://policies.google.com/technologies/partner-sites, or any other URL Google may provide from time to time. To opt out of being tracked by Google Analytics across all sites visit: http://tools.google.com/dlpage/gaoptout.

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The Site also uses WalkMe, a third-party training tool.

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WalkMe allows users to gain insights about behavior around WalkMe content and on the website itself. To provide this insight, WalkMe collects information such as which Walk-Thrus are completed and which WalkMe widgets are opened.

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By default, WalkMe does not collect personally identifiable information (PII) other than IP addresses in logs for security purposes, end users’ approximate geolocation (country and city in which they are located) and masked IP addresses for the ongoing operation of the WalkMe system. WalkMe assigns collected metadata to anonymous random GUID.

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The user identifier, which can also contain PII, is collected and sent according to the end-user identification settings configured for the account. When the end-user ID provider configured in settings is not available (for instance, if the user is not logged in), the WalkMe anonymous generated ID is sent.

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Additionally, WalkMe collects and transfers environment properties such as browser and OS, page URL and title. WalkMe’s privacy policy can be found here: https://www.walkme.com/privacy-policy/.

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Links to Third-Party Websites

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Our Site may include links to websites that are not owned or operated by Canapi. We do not control, and this Policy does not govern, the privacy, security, or other practices of any third-party website. We encourage you to review the privacy policy of such third-party website before you disclose your personal information.

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Children

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The Site is not directed to, nor do we knowingly collect information from, children under 13 years of age. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us using the contact information listed below.

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Changes to this Policy

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We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated Policy on this page and update the Policy’s effective date. Please visit this page periodically to review the most up-to-date version of the Policy. If we make any material changes in the way we collect, use, and/or share your personal information, we will endeavor to provide you with notice before such changes take effect, such as by posting prominent notice on the Site.

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Contact Us

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If you have any questions or concerns about this Policy, please contact us by Peter Underwood, CTO Canapi at pete@canapi.com.

Legal Information