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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, store, share and transfer personal data and information (“Personal Data”) we obtain through our website located at www.sequoiacap.com (the “Sites”), as well as the Internet services that we offer (together, the “Internet Services”).

If you are located in the European Union (the “EU”) or the United Kingdom (the “UK”), this Privacy Policy is for informational purposes only. If you are located in the United States of America or otherwise outside the EU or the UK, by using the Internet Services you consent to such use of your Personal Data and agree to the terms of this Privacy Policy.

Depending on where you are located and your interactions with the Internet Services, certain processing of your Personal Data by Sequoia may be subject to data protection and privacy laws, including the EU’s General Data Protection Regulation (the “GDPR”), the UK Data Protection Act 2018 (the “DPA”) and the California Consumer Privacy Act (the “CCPA”). For example, this may be the case where Sequoia processes the Personal Data of individuals in the EU and the UK who use the Internet Services (the “EU/UK Processing”) or of users of the Sites who reside in California (the “CCPA Processing”).

This Privacy Policy makes clear where its disclosures apply only to the EU/UK Processing or to the CCPA Processing. All other disclosures in this Privacy Policy relate to Personal Data to which the GDPR, the DPA and the CCPA do not apply, as well as to the EU/UK Processing and the CCPA Processing.

This Privacy Policy was updated as of August 24, 2020.

Personal Data We Collect

Information You Submit. This may include: (1) your name, user name and password; (2) contact details, such as your personal or work postal address, email address and phone number; (3) information about your communications with us, including the Personal Data you provide to us in email or in conversations with our employees and personnel; and (4) your marketing preferences, including any consents you have given us. If you provide Personal Data about any person other than yourself, you must ensure they understand how their Personal Data will be used and that they have given their permission for you to disclose the Personal Data to us and our outsourced service providers to use.

Information We Collect Automatically. We automatically collect certain Personal Data 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 or device 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 other 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.

Information We Collect From Third Parties. On occasion, we may receive Personal Data from third party sources, such as where our trusted suppliers provide web analytics and reporting services to us.

Cookies. We 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 Personal Data from minors nor do we target the Sites to minors.

Our Use of Personal Data The following table describes the purposes for which we process the Personal Data referred to above, and any information you give us, as well as the legal basis for the use of Personal Data that is subject to the EU/UK Processing.

Privacy Policy Table

EU/UK Disclosure: Where we require Personal Data to comply with our legal or contractual obligations, the provision of such Personal Data is mandatory. If it is not provided, then we may not be able to provide the Internet Services. In all other cases, the provision of requested Personal Data is optional.

EU/UK Disclosure: We will not use Personal Data to formulate a decision based solely on automated processing (including profiling) which produces legal effects or similarly significantly impacts you.

Our Personal Data Sharing Practices

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 Data needed to perform their functions, but we require that they do not use Personal Data for other purposes. Personal Data is not shared with any unaffiliated third parties for their marketing purposes unless we have obtained your consent to do so in accordance with applicable law.

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.

CCPA Disclosure: We may disclose the following categories of Personal Data to our service providers for the performance of business services on our behalf: (1) identifiers, including your name, user name and password, and contact details, such as your personal or work postal address, email address and phone number; (2) commercial information, including your marketing preferences and any consents you have given us; (3) Internet or other electronic network activity information, including information related to the browser or device you use to access the Sites, your IP address and cookie preferences; and (4) audio, electronic and visual information, including your communications with us and the Personal Data you provide to us in email or in conversations with our employees and personnel. We do not sell your Personal Data and have not sold your Personal Data in the last 12 months. We do not sell the Personal Data of minors.

EU/UK Disclosure: Your Personal Data may be transferred to, processed in and accessed from jurisdictions outside the EU and the UK by Sequoia and the third parties with which we share your Personal Data. Specifically, your Personal Data will be transferred to Sequoia entities and third parties in the United States of America. When we transfer your Personal Data among Sequoia entities, or to other third party organizations, we will do in accordance with the GDPR and/or the DPA, including through the use of European Commission-approved standard contractual clauses, a third party’s binding corporate rules or we where are entitled to rely on one of the other safeguards permitted by the GDPR and/or the DPA.

Your Rights

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

Individuals in Andorra, Argentina, Australia, Canada, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, Uruguay and certain other jurisdictions may have certain rights in relation to their Personal Data. These rights vary, but they may include the right to: (1) request access to and rectification or erasure of their Personal Data; (2) restrict or object to the processing of their Personal Data; and (3) obtain a copy of their Personal Data in a portable format. Individuals may also have the right to lodge a complaint about Sequoia’s processing of their 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 the rights described in this Your Rights section, please email privacy@sequoiacap.com or call 800-991-3121.

If you wish to exercise your rights, we will need to verify your identity. To do so, we will request thatyou match specific pieces of information you have provided us previously, as well as, in some instances, asking you to provide a signed declaration under penalty of perjury that you are theindividual whose Personal Data is the subject of the request. If it is necessary to collect additional information (including Personal Data) 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 Personal Data, 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.

EU/UK Disclosure: You may be entitled to ask Sequoia for a copy of your Personal Data, to correct, delete or restrict processing of it, and to obtain the Personal Data you provide in a structured, machine-readable format and ask us to share this Personal Data to other organizations. You may also have the right to object to processing in some circumstances and can ask us not to send you direct marketing or to carry out profiling at any time. You have the right to lodge a complaint about Sequoia’s processing of your Personal Data with a data protection authority in the place you live, work or where the breach occurred. Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to Sequoia processing your Personal Data, this will not affect any processing that has already taken place. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete Personal Data that we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.

CCPA Disclosure: If you are a California resident, you may be entitled to request access to the Personal Data that Sequoia collects about you, to request that Sequoia deletes your Personal Data and to opt out of the sale of your Personal Data. The CCPA prohibits Sequoia from discriminating against you for exercising your 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. If you are making a request for access, we may not be able to provide specific pieces of Personal Data if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Data, your account with us, or our systems or networks. If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Data again before your request is submitted.

Retaining Your Personal Data

EU/UK Disclosure: Where we process your Personal Data in connection with the Internet Services, we keep the Personal Data to comply with our legal obligations or to communicate with you because you still have another connection with Sequoia. Where we process your Personal Data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after that (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your Personal Data so that we can respect your request in future. We maintain administrative and financial records and use multiple methods to back up our data and systems to ensure reliable data recovery in the event of a significant business disruption, and retain this information in accordance with our Personal Data Retention and Destruction Policy.

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 for the purposes specified in that notice.

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 or Personal Data 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 Personal Data, 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. If you are located in the United States of America or otherwise outside the EU or the UK, by continuing to use the Internet Services after such updates you expressly agree to the terms of the updated 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.