Effective date: July 15, 2024

Greycroft LP, together with its affiliates and funds (“Greycroft,” “we,” or “us”) have created this Privacy Policy to explain how we collect, use, store, share and transfer personal data and information (“Personal Data”) that we gather when you access or use our website located at www.greycroft.com or any other website or data room accessible through such website (collectively, the “Website”). “Personal Data” includes any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. When permitted by law, by using the Website, you consent to such use of your Personal Data and agree to the terms of this Privacy Policy.

If you have a disability, you may access this Privacy Policy in an alternative format by contacting privacy@greycroft.com.

Categories of Personal Data We Collect

The following sections detail the categories of Personal Data that we collect and have collected over the past twelve (12) months. For each category of Personal Data, these subsections also set out our commercial or business purpose for collecting that Personal Data and the categories of third parties with whom we share that Personal Data. More information regarding those sources and categories are set forth in the charts below.

Category of Personal Data	Examples of this Type of Personal Data Collected	Categories of Third Parties with Whom we Share Personal Data
Contact Data	First and Last name, email address, postal address	Service providers, selected recipients
Employment Data	Employer, job title, work email address, web postal address	Service providers, selected recipients
Other Identifying Information You Voluntarily Choose to Provide	Personal information that you send to us	Service providers, selected recipients
Social Media Data	LinkedIn URL	Service providers, selected recipients
Device/IP Information	IP Address, Type of device / operating system / browser used to access the website	Service providers, selected recipients
Web Analytics	Web page interactions	Service providers

Throughout this Privacy Policy, we will refer back to the categories of Personal Data listed above. The following sections provide additional information about how we collect your Personal Data.

Sources of Personal Data

We collect Personal Data about you from you in the following scenarios:

• When you provide such information directly to us.
• When you use our Website
• When you send us an email or otherwise contact us.
• When you use the Website and such information is collected automatically.
  • The Website use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Website, to analyze trends, learn about our user base and operate and improve our Website. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Website. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Website does not support “Do Not Track” requests sent from a browser at this time.
  • We use the following types of Cookies:
    • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Website. Disabling these Cookies may make certain features and services unavailable.
    • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Website, maintain your preferences over time and recognize you when you return to our Website. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
    • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Website such as by collecting information about the number of visitors to the Website, what pages visitors view on our Website and how long visitors are viewing pages on the Website. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Website’s content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at https://www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
  • You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Website and functionalities may not work.
  • To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Website

  • Providing you with the products, services or information you request.
  • Meeting or fulfilling the reason you provided the information to us.
  • Providing support and assistance for the Website.
  • Improving the Website, including testing, research, internal analytics and product development.
  • Personalizing the Website, website content and communications based on your preferences.
  • Doing fraud protection, security and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

• Corresponding with You

  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Greycroft or the Website.

• Meeting Legal Requirements and Enforcing Legal Terms

  • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
  • Protecting the rights, property or safety of you, Greycroft or another party.
  • Enforcing any agreements with you.
  • Responding to claims that any posting or other content violates third-party rights.
  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

Categories of Third Parties with Whom We Share Personal Data

We disclose your Personal Data to the following categories of service providers and other parties. Personal Data, including mobile phone number, will not be sold or shared with third parties for promotional or marketing purposes.

• Service Providers
  • These are third parties that help us provide our Services, including security and fraud prevention providers, hosting and other technology and communications providers, analytics providers, and staff augmentation and contract personnel.
• Selected Recipients
  • These are third parties that we share your Personal Data with at your direction, including:
    • Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Website).
    • Third-party business partners who you access through the Website.
    • Other parties authorized by you

LEGAL OBLIGATIONS

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

BUSINESS TRANSFERS

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

DATA THAT IS NOT PERSONAL DATA

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Website and promote our business, provided that we will not share such data in a manner that could identify you.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as necessary to comply with our legal obligations, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Children

You must be at least 13 years old to use the Website. We do not knowingly collect or solicit personally identifiable information from individuals under 13. If you are under 13, please do not attempt to use the Website or send any personal information about yourself to us. If we learn we have collected personal information from an individual under 13, we will delete that information as quickly as possible.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at legal@greycroft.com.

ACCESS

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information: The categories of Personal Data that we have collected about you.

• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.

DELETION

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Website or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

EXERCISING YOUR RIGHTS

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request by emailing us at: legal@greycroft.com You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

SALES OF PERSONAL DATA

We will not “sell” your Personal Data, as that term is defined in the CCPA, and have not done so over the last 12 months.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of services if you exercise your rights under the CCPA.

Other State Law Privacy Rights

CALIFORNIA RESIDENT RIGHTS

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at legal@greycroft.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Website does not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit https://www.allaboutdnt.com.

NEVADA RESIDENT RIGHTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at legal@greycroft.com with the subject line “Nevada Do Not Sell Request” and providing us with your name. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

1. Third Party Services. The Website may contain links to third party websites or services that are not owned or controlled by Greycroft (“Third Party Services”). When you access Third Party Services, you accept that there are risks in doing so and that Greycroft is not responsible for such risks. Third Party Services are not reviewed, controlled or examined by Greycroft in any way and Greycroft is not responsible for any content, accuracy, privacy policies, or practices or opinions contained therein. These links do not imply Greycroft’s endorsement of or association with any Third Party Service. Greycroft is not liable, directly or indirectly, to anyone for any loss or damage arising from or in connection with use of the Third Party Services, and by using the Website, you release and hold Greycroft harmless from any and all liability arising from your use of any Third Party Service. We encourage you to read the terms and conditions and privacy policy of each Third Party Service that you access.
2. Disclaimer of Warranties. THE WEBSITE, INCLUDING, WITHOUT LIMITATION, ALL CONTENT AND FUNCTIONALITY THEREOF, IS PROVIDED “AS IS,” WITHOUT WARRANTY OF ANY KIND, INCLUDING, WITHOUT LIMITATION, ANY WARRANTIES OF AVAILABILITY, ACCURACY, COMPLETENESS, USEFULNESS, TITLE, NON-INFRINGEMENT, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, AND GREYCROFT (ON BEHALF OF ITSELF AND ITS SUPPLIERS AND LICENSORS) HEREBY DISCLAIMS ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED. NO ADVICE, RESULTS, INFORMATION OR MATERIALS, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU THROUGH THE WEBSITE WILL CREATE ANY WARRANTY NOT EXPRESSLY MADE HEREIN.
3. Limitation of Liability. TO THE GREATEST EXTENT PERMITTED UNDER APPLICABLE LAW, IN NO EVENT WILL GREYCROFT, ITS AFFILIATES (INCLUDING AFFILIATED FUNDS) OR ANY OF ITS OR THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, SUPPLIERS OR LICENSORS (THE “GREYCROFT PARTIES”), BE LIABLE FOR ANY INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES ARISING FROM OR IN CONNECTION WITH THE USE OF, OR THE INABILITY TO USE, THE WEBSITE OR THE CONTENT, EVEN IF ANY GREYCROFT PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY SO SOME OF THE ABOVE LIMITATIONS MAY NOT APPLY TO YOU. IN NO EVENT WILL THE TOTAL LIABILITY OF ANY GREYCROFT PARTY TO YOU FOR ALL DAMAGES, LOSSES, AND CAUSES OF ACTION (WHETHER IN CONTRACT OR TORT, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE OR OTHERWISE) ARISING FROM OR RELATED TO THE TERMS, THE CONTENT, AND/OR YOUR USE OF THE WEBSITE, EXCEED, IN THE AGGREGATE, $100.00.
4. General Information. These Terms are governed by the laws of the State of New York, without regard to the conflicts of laws provisions thereof. In the event of any dispute arising in connection with these Terms, you hereby consent to exclusive jurisdiction and venue in the state and federal courts of New York County, New York. The failure of Greycroft to exercise or enforce any right or provision of these Terms does not constitute a waiver of such right or provision. If any provision of these Terms is found by a court of competent jurisdiction to be invalid, that provision will be limited or eliminated, to the minimum extent necessary, so that these Terms shall otherwise remain in full force and effect and enforceable. You may not assign these Terms or transfer any of your rights or obligations hereunder without Greycroft’s express written consent. These Terms inure to the benefit of Greycroft’s successors, assigns and licensees. These Terms are the entire agreement between you and Greycroft with respect to the subject matter herein.
5. Contact Information: If you have any questions or comments about these Terms, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

privacy@greycroft.com

c/o Compliance 292 Madison Ave., Fl. 8 New York, NY 10017

APPLICANT TRACKING PRIVACY NOTICE

Greycroft LP (“Greycroft”)

Last Updated: September 2022

At Greycroft, we are committed to handling information about you responsibly and we recognize and respect your right to privacy.

This Applicant Tracking Privacy Notice describes the types of personal information we collect about you in connection with the Greycroft Atlas applicant tracking system, how we may use that information, and with whom we may share it. It also describes the measures we take to protect the security of your personal information and how you can reach us to answer any questions you may have about our privacy practices. We also describe the way we use your personal data.

About us

We are a seed to growth venture capital firm that partners with entrepreneurs of all background to build category defining companies. We have deep experience investing in consumer, enterprise, digital health, and fintech sectors around the globe and work as a team to support and advise entrepreneurs and their teams, empowering them to execute their visions. We are a community of over 250 diverse teams, across 30 states and 19 countries, sharing a common goal. Our principal place of business is at 292 Madison Avenue, 8th Floor, New York, New York 10017 and 821 Traction Avenue, 2nd Floor, Los Angeles, California 90013.

Why are you receiving this information?

You are receiving this information because we think you have qualifications and experience that make you a good fit (now or in the future) for our portfolio companies and we think you would be interested in these opportunities.

We have created a personal profile for you in the Greycroft Atlas applicant tracking system. This profile includes your name, job title, current or former employer, and contact information, and may also include publicly available information about you which we obtain from professional social media networks such as LinkedIn. It may also include information we collect from a third-party source (e.g., through Hunt Club or a similar applicant tracking system, from a company for whom you work, other organizations with whom you have dealings, a recruitment agency, an information, or service provider, or from a publicly available record).

Your choices

If you do not want to have a profile in Greycroft’s applicant tracking system or want us to stop contacting you about opportunities, you can let us know at any time by emailing us at privacy@greycroft.com and we will promptly remove your information from our systems.

What personal information do we collect?

Personal information is information that either alone or in combination with other information can directly or indirectly identify you. Examples of personal information collected by us include your name, employer, job title, employment information, telephone number, business and/or personal mailing address(es), email address, and information regarding your job. Should you move along in the applicant tracking process, we may ask for additional sensitive information such as nationality, right to work information, and/or other information regarding your preferences where it is relevant to the services that we may provide to our portfolio companies and/or investors, or your potential employment with us.

We do not collect sensitive types of personal data such as any data about religious, ideological, political or trade union views or activities, or your health. We may request you to voluntarily self-identify sensitive personal data such as gender, race, or intimate sphere information for diversity, equity, and inclusion reporting purposes. How do we use your data and for what purpose?

Greycroft uses your personal data for the following purposes:

1. To consider you for potential roles, opportunities, or jobs at Greycroft, or one or more of its current or prospective portfolio companies
2. To share contact details and other information to facilitate introductions with current and prospective Greycroft portfolio companies
3. To communicate with you (including for the purpose of answering any questions you may have)
4. To invite you to Greycroft events and initiatives
5. To comply with local laws and regulations
6. To analyze your personal data internally

We will use the personal data we collect from you only for the purposes described in this Applicant Tracking Privacy Notice or for purposes that we explain to you at the time we collect your personal data. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) in accordance with any applicable data protection laws, acts, or regulations.

In general, we will process your personal data to carry out our legitimate business interests, where such interests do not override your fundamental rights and liberties. Where required, we will ask you to provide your consent for specific types of personal data (e.g., special categories of personal data).

Who do we share your data with?

Your profile is made available to Greycroft, its affiliates, and Greycroft’s current and prospective portfolio companies (the “Greycroft Entities”). Greycroft Entities utilize the applicant tracking system to see if any candidates may be suitable for vacant roles. If your qualifications may be suitable for an open role, Greycroft may contact you.

International transfers

Greycroft Entities may be located throughout the world. Consequently, your personal information may be used outside your home country. Some countries may not offer the same level of protection as your home country. However, the collection, storage, and use of your personal information will continue to be governed by this notice.

Third-party service providers

Greycroft shares your personal data with third-party service providers, for example, to host your data, to support Greycroft with the administration of the applicant tracking system, and for security purposes. Greycroft will ensure that any third parties accessing your personal data shall comply with the same data protection requirements as Greycroft and the personal data will be used exclusively for the purposes set out in this notice.

How long do we keep your profile?

We will only store your profile for as long as you want it to be available in the applicant tracking system.

You have control of your profile and can request that it is deleted from the applicant tracking system at any time by contacting privacy@greycroft.com and requesting that your information be deleted.

Your rights

Your personal data will not be used for any other purpose and will not be shared with any recipient outside of the ones listed herein.

You have the right, at any time, to request information about our privacy practices and procedures or to access to your personal information.

To the extent that any of your personal information is incorrect or not required for the above purposes, you have the right to request correction, update, deletion, or blocking of such data in accordance with applicable data protection law.

Please note that Greycroft also reserves the right, without notice or your consent, to remove or your delete your profile from the applicant tracking system at any time.

Please email us at privacy@greycroft.com with any queries relating your personal information.

Please click here to see Greycroft’s Privacy Policy.

Updates to this Applicant Tracking Privacy Notice

When we update our Applicant Tracking Privacy Notice, we will take appropriate measures to update this policy on our website, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by applicable data protection laws, acts, or regulations.

You can see when this Applicant Tracking Privacy Notice was last updated by checking the “last updated” date displayed at the top of this notice. How to contact us

How to contact us

If you have any questions or concerns regarding this Applicant Tracking Privacy Notice or the way we process your personal data, or if you wish to exercise your data privacy rights as described above, please contact us by email at privacy@greycroft.com

What Rights Do California Residents Have?

Under the California Consumer Privacy Act of 2018 and/or its implementing regulations (the “CCPA”), residents domiciled in California have certain rights with respect to their personal information. In particular, you may have the right to:

• Request that we disclose, free of charge, the categories and specifics of the personal information we collect about California residents (and/or, if applicable, sell or otherwise disclose to a third party for business purposes).
• Choose to opt-out of the sale of personal information. Currently, however, Greycroft does not sell personal information.
• Request that we delete the personal information we have collected. Following our verification of the request, we will comply with the request and delete any or all the personal information in our possession that we collected from the California resident and/or any or all such personal information in the possession of our service providers, unless otherwise restricted by law or regulation.

Please email us at privacy@greycroft.com to exercise your CCPA rights.

Non-Discrimination for Exercising Your CCPA Right.

We follow the requirements of California Civil Code §1798.125, and will not discriminate against any consumer who exercises the rights under the CCPA.

How long do we keep your personal data?

We will retain your personal data for the period necessary to fulfill the purpose outline in this Applicant Tracking Privacy Policy. We may retain personal data we obtain from you when we have an ongoing legitimate business need to do so, or to fulfill any ongoing contractual obligations with you.

When we have no ongoing legitimate business need or legal obligation to process your personal data, we will either delete or anonymize it or, if this is not possible, we will store your personal data securely and isolate it from further processing until deletion is possible

Recruitment Privacy Notice

The following provides further information about our handling of your personal information when you apply for a job with us. Please note that this is supplementary to the fair processing information set out above, and you have the same rights as set out above in the recruitment context too.

In connection with seeking employment with us, we may collect your CV, application form, tests and assessment, interview materials, and information and opinions related to you.

We may also collect sensitive data including any of the following types of information: racial or ethnic origin, political opinions, religious or philosophical beliefs, union membership, physical or mental health, sexual life, criminal offenses, or criminal proceedings or convictions.

Such information is maintained for the purpose of evaluating your potential employment with us. Information you provide to us for this purpose may be shared with selected third parties for the purpose of assessing your potential employment. You should note that your application will be subject to verification. This will involve your references being taken up and any qualification which is indicated on your application being verified by contacting the appropriate body.

The information about you will be used for the purpose of determining your suitability for employment with us. It may also be held for statistical analysis. It may be used for the purposes of legal proceedings (including prospective legal proceedings); obtaining legal advice; establishing, exercising, or defending legal rights; compliance with any legal obligation to which the firm is subject; to maintain the security of the firm and its personnel; the prevention and detection of crime or fraud; and compliance with any request from regulatory authorities or other relevant public authorities or agencies.

If your application for employment is unsuccessful, then the information may be retained by us, but in any case, for no longer than is necessary for these purposes.