Effective Date: June 15, 2020
Thank you for visiting thecolumngroup.com (the “Site”), owned and operated by The Column Group, LLC (“TCG,” “we,” or “us”). TCG respects your privacy and, whether you are visiting the Site as an investor, founder or member of the general public, you are entitled to the protection of your personal information. Please read this Privacy Policy to learn how we treat your personal information.
By using or accessing our Site in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of TCG’s Site is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we that use in this Privacy Policy without defining them shall have the definitions given to them in the Terms of Use.
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1. What this Privacy Policy Covers.
This Privacy Policy covers important information and disclosures relating to how we treat Personal Data that we gather when you access or use our Site, but does not cover the practices of our portfolio companies or any entity with whom we have an investment relationship, even if you are able to access such entity’s website through a link of this Site. It also does not apply to information obtained or disclosed in offline correspondence, through personal contacts with TCG representatives. Please note that you may have additional rights to control the use and disclosure of your Personal Data. Residents of California should refer to the relevant subsections below. If you have a disability, you may access this Privacy Policy in an alternative format by contacting administrator@thecolumngroup.com.
Use of the term “Personal Data” herein means 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.
2. Categories of Personal Data We Collect.
Please find details regarding the categories of Personal Data that we collect and have collected over the past twelve (12) months below
- Contact information and other identifying information that you voluntarily choose to provide to us (e.g., first and last name, and email) (such Personal Data, “Contact Information”).
- Usage and web analytics (e.g., IP address and related location information, interactions with our Site, interactions with our other web properties, device and/or browser information) (such Personal Data, “Usage Analytics”).
- Other information you may provide to us through third-party interactions with our Site or other web properties.
3. Sources of Personal Data.
We collect Personal Data about you from the following categories of sources:
- You
- When you provide such information directly to us.
- When Personal Data about you is automatically collected in connection with your use of our Services.
- Third Parties
- Vendors: For example, we may use third party providers to administer the Site or our funds, or to process web analytics information.
4. How We Use Your Personal Data.
We process your Personal Data for the following business purposes:
- To meet or fulfill the reason you provided Personal Data to us; including personalizing Site content and communications, responding to inquiries and fulfilling requests, providing support and assistance for the Site, personalizing Site content and communications, delivering our other web properties (e.g., newsletters, emails), to facilitate events, etc.
- To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Site.
- To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms or this Privacy Policy.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- For any other business purpose 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”).
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.
As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional emails or email you about your use of the Site. Also, we may receive a confirmation when you open an email from us, which helps us improve our Site. If you do not want to receive communications from us, please indicate your preference by emailing us at administrator@thecolumngroup.com.
5. How We Share Your Personal Data.
We disclose your Personal Data as indicated above to the following categories of service providers and other parties:
- Service Providers
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- Categories of Personal Data Shared: We disclose Contact Information and Usage Analytics to our service providers.
- Purposes for Sharing: These third-party service providers help us provide our services and operate our business, including analytics providers, security and fraud prevention providers, hosting and other technology and communications providers, and staff augmentation and contract personnel. When we share your Personal Data with service providers, they may only use your Personal Data for specific purposes relating to assisting us with running our business.
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- Successors to Our Business
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- Categories of Personal Data Shared: All Personal Data.
- Purposes for Sharing: Your Personal Data may also 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).
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6. Security and Retention.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, and administrative security measures and storage and processing practices based on the type of Personal Data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. We retain Personal Data about you for as long as necessary to provide our Site and/or services to you, comply with our legal obligations, resolve disputes, or as 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.
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 or storing data over the Internet 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.
7. Personal Data of Minors.
We do not knowingly collect or solicit Personal Data about children under 13 years of age. If we learn that we have collected personal information from an individual under the 13 years of age, we will delete such information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at administrator@thecolumngroup.com.
8. Privacy Rights of California Residents.
If you are a resident of California, you have the rights set forth in this section. Please note that we may process Personal Data in connection with our provision of certain Site services and, 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 Personal 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 administrator@thecolumngroup.com.
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including the:
- Categories of Personal Data that we have collected about you.
- Specific pieces of Personal Data that we have collected about you.
- Categories of sources from which that Personal Data was collected.
- Business or commercial purpose for collecting your Personal Data.
- Categories of third parties with whom we have shared your Personal Data.
- Categories of Personal Data shared with third parties for a business purpose over the past 12 months, if applicable.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you, subject to certain exceptions under the CCPA: for example, we may need to retain your Personal Data to provide you with the Site services 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 CCPA 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 either the person about whom we have collected Personal Data or are an agent authorized by that person, 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 may submit a Valid Request by emailing us at administrator@thecolumngroup.com.
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 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.
We Do Not Sell Your 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 also do not sell the Personal Data of minors under 16 years of age.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not deny you access to our Site or provide you a lower quality of services if you exercise your rights under the CCPA. If you have any questions about this section or whether any of the above rights apply to you, please contact us at administrator@thecolumngroup.com.
9. Privacy Rights of Other United States Residents.
California Resident Rights
California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, under California Civil Code Sections 1798.83-1798.84. If you would like to submit such a request, please contact us at administrator@thecolumngroup.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. If you are a Nevada Resident, you can exercise this right by contacting us at administrator@thecolumngroup.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.
10. Changes to This Privacy Policy.
We’re constantly trying to improve our Site and services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the TCG website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Site and/or services, and you are still responsible for reading and understanding them. If you use the Site and/or services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
11. Contact Information.
If you have any questions or comments about this Privacy Policy, 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: administrator@thecolumngroup.com.
