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Sequoia Privacy Policy

Sequoia Capital Operations LLC, together with its affiliates and funds (“Sequoia”, “us”, “our” or “we”), have created this Privacy Policy to explain how we collect, use and share information we obtain through our website located at https://www.sequoiacap.com// (the “Sites”), as well as Internet services that we offer (together, the “Internet Services”). Because the Internet is global, information about you that we collect or that you submit may be transferred to, processed in, and held in countries (including the United States) other than the one in which you reside. By using the Internet Services, you consent to such use of your information and agree to the terms of this Privacy Policy.

This Privacy Policy was updated as of December 23, 2019.

Information We Collect and Use

Information You Submit. To obtain access to the Sites and to receive certain Internet Services, you may be required to login and provide certain personal data and information about yourself (for example, your username, name and password) (“Personal Data”). We use Personal Data to fulfill your requests for Internet Services, as well as other products and services (together, the “Services”), to monitor and improve our Services, and to contact you from time to time about us and the Services.

Information We Collect Automatically. We automatically collect certain information to help us understand how you use the Internet Services (which we will refer to in this Privacy Policy collectively as “Usage Data”). For example, each time you visit the Sites we may automatically collect your IP address, browser and computer type, access time, the webpage from which you came, and the webpage(s) that you access during your visit. We may combine Usage Data with Personal Data in a manner that enables us to trace Usage Data to an individual user. Some web browsers may have “do not track” settings. The Sites do not honor “do not track” settings.

We also may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive) to keep track of your use of the Internet Services, to validate your identity, to remember your password and preferences, to tailor the Internet Services to your account and to meet your interests, and to improve the quality of the Internet Services. Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain Internet Services may not function properly. 

Children. We do not knowingly collect information from minors nor do we target the Sites to minors.

Automated Decisions. We will not use personal information to formulate a decision based solely on automated processing which produces legal effects or similarly significantly impacts the person.

Our Information Sharing Practices

We do not sell Personal Data, and have not done so for the 12 months prior to the effective date of this policy.

We employ other companies and individuals to perform functions on our behalf, such as for analyzing data and providing certain of the Internet Services. These third-party service providers have access to personal information needed to perform their functions, but we require that they not use personal information for other purposes. Personal Data is not shared with any unaffiliated third-parties for their marketing purposes.

We may share Personal Data with third parties (1) in response to subpoenas, court orders, regulatory requests or legal process, or to establish, protect or exercise our legal rights and interests or defend against legal claims; (2) if we believe it is necessary in order to investigate, prevent or take action regarding inappropriate or illegal activities, fraud, or situations involving potential threats to the safety of any person or property; (3) if we believe it is necessary to investigate, prevent, or take action regarding inappropriate use of the Internet Services; (4) to our parent company, subsidiaries, joint ventures, or other companies under common control with us (in which case we will require such entities to honor this Privacy Policy); and (5) as part of a corporate transaction with a successor or affiliate or in connected with any acquisition, merger or sale of assets.

Your Rights

We have controls in place designed to ensure that the information we have is relevant, accurate, and appropriate for the purposes used. If you believe that any data about you is inaccurate, please let us know by contacting us at privacy@sequoiacap.com. Please note that any Personal Data that we have copied may remain in back-up storage for some period of time after your request, and that if you delete certain information you may not be able to use our services in the future without re-submitting such information. Also, please note that we will maintain Personal Data in our database whenever we are required to do so by law or regulation.

Individuals in Andorra, Argentina, Australia, California, Canada, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their personal data; (ii) restrict or object to the processing of their personal data; and (iii) obtain a copy of their personal data in a portable format. Individuals may also have the right to lodge a complaint about the processing of personal data with a data protection authority. The rights described herein are not absolute and may not be applicable to you. We reserve all of our rights available to us at law in this regard. If you wish to exercise any of these rights please email privacy@sequoiacap.com or call 800-991-3121.

The California Consumer Privacy Act (“CCPA”) prohibits covered businesses from discriminating against you for exercising applicable CCPA rights.

Under California Civil law, Californians are also entitled to request information relating to whether a business has disclosed personal data to any third parties for the third parties’ direct marketing purposes. Californians who wish to request further information about our compliance with this statute or who have questions, more generally, about our Privacy Policy and our privacy commitments and our Sites should contact us at privacy@sequoiacap.com.

If you wish to exercise your rights, we will need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose personal information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. We will process your request within the time provided by applicable law

SEC Regulations S-P, S-AM and the Gramm-Leach-Bliley Act

Some regulators such as the Securities and Exchange Commission, the U.K. Information Commissioner and the Federal Trade Commission have adopted rules that require financial institutions, like Sequoia, to provide privacy policy notices to their clients. If you are a natural person who invests with us, that notice will govern how we use your personal data.

Security

We have implemented measures to help protect Personal Data from loss, misuse or unauthorized access or disclosure. While we strive to protect Personal Data, we cannot guarantee its security.

Links

The Sites may contain links to other websites. We are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information to such websites.

Changes

We may update this Privacy Policy from time to time. If under any such update we make any material change to the way in which we treat your User Information, we will inform you of such change via e-mail or by posting a notice on relevant areas of the Sites. Any updated version of this Privacy Policy will be effective as of the date set forth therein. By continuing to use Internet Services, you expressly agree to the terms of the Privacy Policy.

Questions

If you have any questions about this Privacy Policy, please feel free to contact us by e-mail at privacy@sequoiacap.com.