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Initialized Privacy Policy

Updated: March 1, 2024


This Privacy Policy (“Policy”) describes how Initialized Capital Management, LLC (“Initialized,” “we,” “our,” and/or “us”) collects, uses, and discloses certain Personal Information (defined below) obtained through our website (including all subdomains, “Site”), which is located at https://initialized.com. This Policy applies only to information collected through the Site and therefore does not apply to data we collect in other contexts.

By visiting our Site and/or using the features made available to you on the Site (collectively, the “Site Services”), you are agreeing to the terms of this Policy.


What Information We Collect and Maintain About You


We collect information from you directly when you provide it to us through the Site. We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Site Services.


Personal information collected through the Site. We may collect the following “Personal Information” about you: (i) identifiers and similar information, such as your name, address, email address, online identifies or other similar identifiers; (ii) characteristics of protected classifications under applicable law; (iii) commercial information, including your marketing preferences; (iv) Internet or other electronic network activity information, including information related to the browser or device you use to access the Site, your IP address and your cookie preferences; (v) geolocation information, such as information about your location or the location of your device, (vi) professional or employment information, such as when an individual applies for employment; and (vii) audio, electronic, visual or other similar information, such as if you request support related to the Site or other matters.


Personal information collected through online community platform. If you accept an invitation to become a member of our portfolio company online community platform, we will collect information related to creating and maintaining the platform. This may include information related to creating your account (such as your name and email address), as well as any information you disclose through the platform.


Web log data. When you use the Site Services, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site Services, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site Services, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.


Cookies. We also use cookies on the Site Services. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site Services to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site Services during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site Services, and the link you used to leave the Site Services. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site Services may not operate correctly.


Third-party plugins. Our Site Services may include plugins from other companies, including social media companies (e.g., a “Like” button). These plugins may collect information, such as information about the pages you visit, and share it with the company that created the plugin even if you do not click on the plugin. These third-party plugins are governed by the privacy policies and terms of the companies that created them.


Third-party online tracking. We also may partner with certain third parties to collect, analyze, and use some of the Personal Information described in this Policy. For example, we may allow third parties to set cookies or use web beacons on the Site Services or in email communications from us. This information may be used for a variety of purposes, including online website analytics or interest-based advertising.


Aggregated and deidentified information. From time to time, we may also collect and share aggregated or deidentified information about our users, such as by publishing a report on trends in the usage of the Site. Such aggregated or deidentified information will not identify you personally.


How We Use Your Information


We use the information that we collect for a variety of purposes. These purposes include, for example:

  • • Provide you with our Site Services;
  • • Respond to your questions or requests concerning the Site Services;
  • • Fulfill the terms of any agreement you have with us;
  • • Send you information about our Site Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails;
  • • Deliver confirmations, account information, notifications, and similar operational communications;
  • • Improve your user experience and the quality of our products and Site Services;
  • • Comply with legal and/or regulatory requirements;
  • • Aggregate and deidentify information;
  • • Analyze how visitors use the Site Services and various Site Services features, including to count and recognize visitors to the Site Services;
  • • Create new products and Site Services; and
  • • Manage our business.


With Whom and Why We Share Your Information


We share your information with other parties for a variety of purposes, as described below.


Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site Services uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.


The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Site currently does not respond to “do not track” browser headers, you can limit tracking through these third-party programs and by taking the other steps discussed above.


Third-party service providers. Our online community platform may use third-party service providers that perform Site Services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.


We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.


Legal Purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:

  • • To comply with applicable law or a court order, subpoena, or other legal process;
  • • To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • • To establish, protect, or exercise our legal rights or defend against legal claims; or
  • • To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.


Your Choices


If you want to learn more about the Personal Information that Initialized has about you, or you would like to update, delete, or change that information, please contact us by email at legal@initialized.com.


You may also opt out of receiving marketing emails from us by following the instructions in those emails.


External Links


The Site may contain links to third-party websites. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our Site, you do so at your own risk.


Data Security


We employ physical, technical, and administrative procedures to safeguard the Personal Information we collect online. However, no website is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Site Services or to us, and you transmit such information at your own risk.


Data Retention


We retain Personal Information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain Personal Information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your Personal Information, we do so in a way that prevents that information from being restored or reconstructed.


International Users


The information that we collect through or in connection with the Site Services is transferred to and processed in the United States for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site Services or by providing any Personal Information to us, you expressly consent to such transfer and processing.


California Consumer Privacy Act (“CCPA”) Disclosure


If you are a California resident, you may be entitled to request access to the categories or specific pieces of Personal Information that Initialized collects about you, to request that Initialized deletes or corrects your Personal Information and to opt out of the sale and/or sharing of your Personal Information. Although California residents may have the right to opt out of the sale and sharing of personal data, Initialized does not sell or share Personal Information as the terms “sell” and “share” are used under the CCPA, to third parties, including without limitation Personal Information of minors, and we have not sold or shared such Personal Information in the last 12 months. The CCPA prohibits Initialized from discriminating against you for exercising your applicable CCPA rights.


If you wish to exercise any of the rights described in this CCPA disclosure section, please contact us at legal@initialized.com. In order to respond to a request, you will be required to supply a valid means of identification as a security precaution. Depending on the sensitivity of the information in question, we may require additional proof of identification. We will not disclose or delete any information until the individual’s identity is verified. If an agent makes a request on your behalf, they will be required to verify the request by submitting your written authorization, and we may still ask that you verify your identity with us before we can proceed with the request. We will not honor any requests from agents until authorization is verified. We will maintain records of consumer requests made under CCPA and how we responded to those requests in accordance with the CCPA.


Children


Content on the Site Services is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect Personal Information from children under the age of 13.


Changes to this Policy


We may make changes to the Site Services in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Site Services, so you should review this page periodically. You may see when this Policy was last updated by checking the date displayed at the top of this notice.


How to Contact Us


Should you have any questions or concerns about this Policy, you may contact us at legal@initialized.com.