‍Our Commitment to User Privacy:

‍

This Privacy Policy and Notice of State Privacy Rights (this “Policy”) describes how 6Lock Inc. protects and manages your personal data, including:

‍

• What data we collect when you sign-up for, use, or engage with any of our applications, products, services, or websites (collectively, the “Services”);
• How we manage data from the beginning of your engagement onwards;
• The choices you have regarding how data is managed.

‍

This Policy applies to information we collect in connection with your access and use of our Services. Please read this Policy carefully. By continuing to use or access our Services, you are consenting to the practices described in this Policy.

‍

We Limit Use of Your Personal Data to:

‍

• Providing, maintaining and improving our Services;
• Verifying your identity, where applicable;
• Communicating with you about new and existing Services; and
• Protecting the legal rights, property and safety of us, our Services and our users.

‍

We Collect and Use Data:

‍

Data We Collect:

‍

Your name, email address, phone number, birth date, government-issued identification number, where necessary, payment card and bank information, if applicable, as well as other information you may be asked to provide when signing-up for an account, providing identity verification or engaging in a transaction.

‍

Other Data:

‍

• Transaction Data: when, where and how a transaction takes place including, but not limited to, the devices and payment methods used;
• Device Data: hardware model, operating system, unique device identifiers, mobile network data as well as other data generated by a device's interaction with our Services;
• Location Data: to prevent fraudulent use of our Services;
• User Data: browser data, Internet Protocol (“IP”) addresses and other data describing user engagement;
• Cookies: small data files we may store on your computer or mobile device memory to help us manage your engagement with our Services, including gathering aggregated data about engagement;
• Beacons: small electronic images we may use in our Services and emails to deliver cookies and measure user engagement.
• Information to Enhance your Experience: other data such as a profile picture that may enhance your experience. 

‍

Sources of Information:

‍

• We also check that you are using our Services legally and are eligible for the Services you want to use. We protect the Services from fraudsters who may put you and your money at risk. To do this, we may collect data about you from companies that help us verify your identity, if applicable, prevent fraud or assess risk.
• We collect (and have collected during at least the 12-month period preceding the effective date of this Policy) information about you from the following categories of sources:some text
  • You directly, when you submit information to us or allow us to access information,
  • Investment funds (e.g., venture funds or private equity firms) that you have invested in or otherwise transact business with and that use our Services,      
  • Your devices and how you interact with our Services, and
  • Other sources, including: some text
    • Identity Verification. Information from third-party identity verification services and publicly available sources, including your government-issued identification number.
    • Eligibility, Compliance, and Fraud. Information about you from third parties for any investigation, eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This may include, without limitation, the receipt and exchange of account or transaction-related information with any consumer reporting agency or credit bureau.

‍

We Share Personal Data Under Controlled Circumstances:

‍

• With third parties who may access data about you to provide you with the Services;
• With third-party service providers (such as lawyers, bankers, auditors, insurers, investment bankers, or others performing professional services on our behalf) who may access data about you to perform functions on our behalf;
• With financial institutions, processors, payment card associations and other entities that are involved in the payment process;
• With government and law enforcement where reasonably necessary to comply with applicable law, regulation, legal process, or governmental request;
• With others where reasonably necessary to protect the security or integrity of our Services or user safety;
• In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business;
• With your consent.

‍

We may share aggregated and anonymized information that does not specifically identify you or any individual user of our Services.

‍

We do not share your Personal Data: 

‍

• With third party merchants or advertisers;
• With funds other than funds in which you are invested (except on an anonymized, aggregated basis);
• Other than in accordance with this Privacy Policy;

‍

Security:

‍

We take reasonable measures, including administrative, technical and physical safeguards to help protect your personal data from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction.

‍

We maintain commercially reasonable security standards and procedures with a view to preventing unauthorized access to your data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, two-factor authentication, PII encrypted data vault, firewalls and server authentication to protect the security of your data.

‍

Choices:

‍

• Personal Data: You can change or correct data about yourself through your 6Lock account at any time or by emailing us at privacy@6lock.com. You can also email us if you wish to deactivate your account. We may retain data about you for a period of time consistent with applicable law.
• Location Data, if applicable: Our mobile applications may require location data. If you do not grant us access to this data, then you may not be able to use our Services. If you grant access to location data but later revoke this access your mobile device may no longer be able to use our Services. You may also uninstall our Services to stop collection of location data.
• Cookies: You can set your browser to reject cookies, but our Services may not function properly in this setting.
• Notifications: Our Services may ask you for permission to send notifications to your device. Our services will still work if you do not grant us permission to send you notifications.
• Website Tracking: Certain websites you visit may provide options regarding advertisements you receive. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info.
• Do Not Track: Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Services do not currently change the way they operate based upon detection of a Do Not Track or similar signal.

‍

Cookies and Tracking Technologies:

‍

We and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information based on IP addresses. You can control the use of cookies at the individual browser level. 

‍

Cookies are small text files that are placed on your computer by websites and services that you visit or access. They are widely used to make websites and services work and function with greater efficiency, and to provide information about our users’ experience during use of, or interaction with, our websites, and Services. Some cookies last only for the duration of your web session and expire when you exit your browser; other cookies may last for longer than your web session, including after you exit your browser, for example by remembering you when you return to our website. The table below explains the cookies that we and our third-party partners use and why.

‍

Functional Cookie for Preferences and Settings: These cookies are used to record a user’s choice and settings that enable our websites and Services to operate correctly or that maintain your preferences over time and may be stored on your device.

‍

Functional Cookie for Sign in and Authentication: When you sign into a website or Service using your 6Lock account, we may store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the website without having to sign in again on each page. You can also save your sign-in information, so you do not have to sign in each time you return to the site.

‍

Analytics Cookie: To provide our products and improve your user experience on our websites and with our Services, we use cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service or to our blog and to develop other statistics about the operations of our Services. This may include cookies from us and from third-party providers. We use the information to compile reports and to help us improve our websites and Services.

‍

How to Control Cookies

‍

Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. For example, in most modern browsers, you can block or delete cookies by clicking Settings >  6Lock > Cookies. Instructions for blocking or deleting cookies in other browsers may be available in each browser's privacy or help documentation. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

‍

Certain features of our Services may depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.

‍

Third-Party Analytics Services:

‍

We and our third-party service providers may sometimes use technologies to engage in data analytics, auditing, measurement, research, reporting, and debugging on our Services and to measure interactions with our services, such as tracking referral credits. 

‍

Third-Party Data:

‍

The Services may contain hyperlinks to other websites or locations that we do not control and are operated and controlled by third parties (“Third-Party Websites”). Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites.

‍

Dispute Resolution:

We commit to resolve complaints about our collection or use of your personal information. Persons with inquiries or complaints regarding our Privacy Policy should first contact us by email at privacy@6lock.com. 

‍

California Privacy Rights:

‍

We incorporate this section to identify additional consumer protections that were recently established under California law.  

‍

When you use the Service, we may automatically collect personal information such as technical data about the device that you are using and your browsing patterns.  We collect this information by using cookies, server logs and similar technologies.  You may choose to give us additional personal information, such as your name, employer, address, email and telephone number. We also collect the following information from you when you use the Services: (1) the city and state in which you live, (2) information you voluntarily provide to us, and (3) inferences made based on items (1) and (2).

‍

We use this personal information in several ways, including providing the Services to you and our customers, monitoring website activity, and enabling you to communicate with us and request information. 

‍

We may disclose (which may constitute a “sale” under California law) the following information to our customers: (1) the city and state in which you live, (2) information you voluntarily provide to us, and (3) inferences made based on items (1) and (2). Other than according to the foregoing sentence, we do not and will not sell the personal information that we collect from you through the Services, as described in this Privacy Policy. 

‍

Under no circumstance do we “sell” your personal information to any party other than our customers that you are invested in. Our customers use this information in connection with the management of their fund.

‍

We will not charge or penalize you for requesting information and otherwise exercising your rights as described in this Privacy Policy, but we may reasonably limit the number of requests you may make and impose appropriate charges as permitted by law.  

‍

In some instances, you may request that we delete your personal information, consistent with your general right to request that we, as a business, delete any of your personal information that we have collected from you. We will comply with your requests to the fullest extent allowed by applicable law.

‍

If you use an authorized agent to request information or exercise your rights, that authorized agent must meet the same authentication requirements that apply to the requests that we may receive directly from you.  We may verify requests made by authorized agents to ensure security and comply with regulations and our internal policies.

‍

Mandatory Privacy Disclosures

‍

We also make the following disclosures for the purpose of complying with California law:

‍

• We collected the following categories of personal information in the last 12 months: characteristics of protected classifications under applicable law, internet or other electronic network activity information, geolocation data, electronic, or similar information and inferences drawn from the information above.
• The sources of personal information we collected are: directly from you and from certain partners that operate the Services.
• The business or commercial purpose of collecting the personal information above is described in more detail in the section of this Privacy Policy under the heading “How We Use Your Personal Information.”
• We shared the information we collected with certain of our customers. As defined by California law, this may mean that we “sold” the personal information we collected to certain of our customers. Our business and commercial purpose of sharing or “selling” personal information is to provide the Services to our customers or facilitate transactions on your behalf.

‍

Your California Privacy Rights

‍

To exercise any of the rights list below, please email us at privacy@6lock.com.

‍

• Right to Know. You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of that personal information. You may also request that we disclose to you the purposes and categories of third parties with whom such personal information is shared.
• Right to Access. You have the right to request, up to two times per year, access to categories and specific personal information about you that we have collected and shared with our customers.
• Right to Delete. You have the right to request that we delete personal information we collect from you, subject to exceptions allowed by law. 
• Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you, subject to exceptions allowed by law.
• Right to Opt Out of Sale or Sharing. You have the right to “opt out” of the “sale” or “sharing” of your “personal information” to or with “third parties” (as each of those terms is defined by California law).
• Right to Not Receive Discriminatory Treatment. You have the right to not be discriminated against on the basis of exercising the rights above.

‍

Colorado Privacy Rights

‍

Colorado law provides Colorado residents with the following rights. To exercise any of these rights, please email us at privacy@6lock.com.

‍

• Right to Access. You have the right to see and know what personal data we have collected about you. We will provide it in a usable format.
• Right to Delete. You have the right to request that we delete the personal data we have collected about you, subject to exceptions allowed by law.
• Right to Correct. You have the right to request that we correct inaccurate personal data.
• Right to Opt Out of Targeted Advertising and Sale of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data (as each of those terms is defined by Colorado law).

‍

Connecticut Privacy Rights

‍

Connecticut law provides Connecticut residents with the following rights. To exercise any of these rights, please email us at privacy@6lock.com.

‍

• Right to Access. You have the right to see and know what personal data we have collected about you. We will provide it in a usable format.
• Right to Delete. You have the right to request that we delete the personal data we have collected about you, subject to exceptions allowed by law.
• Right to Correct. You have the right to request that we correct inaccurate personal data.
• Right to Opt Out of Targeted Advertising and Sale of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data (as each of those terms is defined by Connecticut law).

‍

Utah Privacy Rights

‍

Utah law provides Utah residents with the following rights. To exercise any of these rights, please email us at privacy@6lock.com.

‍

• Right to Access. You have the right to see and know what personal data we have collected about you. We will provide it in a usable format.
• Right to Delete. You have the right to request that we delete the personal data we have collected about you, subject to exceptions allowed by law.
• Right to Correct. You have the right to request that we correct inaccurate personal data.
• Right to Opt Out of Targeted Advertising and Sale of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data (as each of those terms is defined by Utah law).

‍

Virginia Privacy Rights

‍

Virginia law provides Virginia residents with the following rights. To exercise any of these rights, please email us at privacy@6lock.com.

‍

• Right to Access. You have the right to see and know what personal data we have collected about you. We will provide it in a usable format.
• Right to Delete. You have the right to request that we delete the personal data we have collected about you, subject to exceptions allowed by law.
• Right to Correct. You have the right to request that we correct inaccurate personal data.
• Right to Opt Out of Targeted Advertising and Sale of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data (as each of those terms is defined by Virginia law).

‍

Changes to this Policy:

‍

We can change this Policy. When the changes impact how we use your data in important ways, we’ll tell you first by email.

‍

We may amend this Policy from time to time by posting a revised version and updating the “Last Modified Date” above. Any modifications will be effective upon our posting of the new terms or upon implementation of the new changes in the Services. The revised version will be effective on the “Last Modified Date” listed. We will provide you with reasonable prior notice of material changes in how we use your information, including by email, if you have provided one. If you disagree with these changes, you may cancel your account at any time. If you keep using our Services, you consent to any amendment of this Policy.

‍

Contact Details:

‍

If you have questions or comments, feel free to email us at privacy@6lock.com or write to us at 115 Wild Basin Road, Suite 302, Austin, Texas 78746 Attention:  David Beisner.