Last Updated April 12th, 2021
1. PERSONAL INFORMATION WE COLLECT
Personal Information You Provide: We collect the following categories of personal information from you when you sign up as a prospective or existing investor:
- Investment Information: If you submit an application to Blockchange in order to participate in a potential investment, we may collect certain information in connection with your subscriber agreement, including your name, email address, phone number, mailing/billing addresses, social security number, financial information necessary to process your wire payments, and other similar identification information.
- Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication information is optional to you.
Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Edge, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log Information: Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol (“IP”) address, browser type and settings, the date and time of your request, and how you interacted with the Site.
- Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
Personal Information We Process on Behalf of Our Business Clients: In order to provide the Service, we collect personal information described above through our sign-up form about individuals who work on behalf of our fund and other investor group clients (our “Business Clients”). We process that information pursuant to our subscriber agreements and other agreements with our Business clients. We operate as a processor with respect to such personal information and process such information on behalf of our business clients with the individuals whose personal information we process on behalf of our Business Clients. If you are such an individual and would like to access, correct, or request deletion of your information, please contact the Business Client that you interact with directly.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
2. HOW WE USE PERSONAL INFORMATION
We may use personal information for the following purposes:
- To provide you with the Service, including allowing you to participate in potential blockchain related investment opportunities;
- To respond to your inquiries, comments, feedback, or questions;
- To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
- To analyze how you interact with our Service;
- To maintain and improve the Service;
- To develop new products and services;
- To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
Blockchange does not sell your personal information. In certain circumstances we may share the categories of personal information described above without further notice to you, unless required by the law, with the following categories of third parties:
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share personal information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, client relationship management and client support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store personal information in the course of performing their duties to us.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your personal information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
4. CALIFORNIA PRIVACY RIGHTS DISCLOSURES
Where provided for by law and subject to any applicable exceptions (such as if certain personal information you have provided to us is protected under the Gramm-Leach Bliley Act), California residents may have the right:
- To know the categories of personal information that Blockchange has collected about you, the business purpose for collecting your personal information, and the categories of sources from which the personal information was collected;
- To access the specific pieces of personal information that Blockchange has collected about you;
- To know whether Blockchange has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information;
- To have Blockchange, under certain circumstances, delete your personal information;
- To instruct businesses that sell personal information to stop doing so – Blockchange, however, does not sell personal information; and
- To be free from discrimination related to the exercise of these rights.
If you would like to exercise any or all of these rights, you may do so by contacting us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
Our Service is not directed to individuals who are under the age of 18. Blockchange does not knowingly collect personal information from children under the age of 18. If you have reason to believe that a child under the age of 16 has provided personal information to Blockchange through the Service please contact us and we will endeavor to delete that information from our databases.
6. LINKS TO OTHER WEBSITES
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. Please keep this in mind when disclosing any personal information to Blockchange via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
8. INTERNATIONAL USERS
The Service is controlled and operated by Blockchange in the United States. Blockchange makes no representations regarding privacy and data protection laws and regulations of jurisdictions outside of the United States. By using our Service, you understand and acknowledge that your personal information will be transferred from your location to our facilities and servers in the United States, where data protection laws may differ from those in your jurisdiction.
9. YOUR CHOICES
In certain circumstances providing personal information is optional. However, if you choose not to provide personal information that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to request updates or corrections to your personal information.
11. CONTACT US
Gramm-Leach-Bliley Act Notice:
The following notice applies to you if you are a natural person who uses the Services:
|FACTS||WHAT DOES BLOCKCHANGE VENTURES LLC AND ITS AFFILIATES ("BLOCKCHANGE") DO WITH YOUR PERSONAL INFORMATION?|
|Why?||Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.|
The types of personal information we collect and share depend on the product or service you have with us. This information can include:
When you are no longer our customer, we continue to share your information as described in this notice.
|How?||All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Blockchange chooses to share; and whether you can limit this sharing.|
|Reasons we can share your personal information||Does Blockchange share?||Can you limit this sharing?|
|For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus||Yes||No|
|For our marketing purposes — to offer our products and services to you||Yes||No|
|For joint marketing with other ﬁnancial companies||Yes||No|
|For our affiliates' everyday business purposes — information about your transactions and experiences||No||We don't share|
|For our affiliates' everyday business purposes — information about your creditworthiness||No||We don't share|
|For our afﬁliates to market to you||No||We don't share|
|For nonafﬁliates to market to you||No||We don't share|
|Questions?||Contact us at [email protected]|
|Who we are|
|Who is providing this notice?||This notice is being provided on behalf of Blockchange Ventures LLC and its affiliated companies listed below.|
|What we do|
|How does Blockchange protect my personal information?||To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured ﬁles and buildings.|
|How does Blockchange protect my personal information?||
We collect your personal information, for example, when you
We may also collect your personal information from others, such as credit bureaus, affiliates, or other companies.
|Why can't I limit all sharing?||
Federal law gives you the right to limit only
State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.
|Affiliates||Companies related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies. Our affiliates include Blockchange Ventures I GP LLC, Blockchange Ventures II GP LLC, Blockchange Ventures I, LP, Blockchange Ventures II, LP, and Blockchange Ventures III, LP.|
|Nonaffiliates||Companies not related by common ownership or control. They can be ﬁnancial and nonﬁnancial companies.|
|Joint marketing||A formal agreement between nonafﬁliated ﬁnancial companies that together market ﬁnancial products or services to you.|
|Other important information|
Vermont Residents Only: We will not share information we collect about you with nonaffiliated third parties, except as permitted by law, including, for example, with your consent or to service your account, or for joint marketing. We will not share information about your creditworthiness with our affiliates or for joint marketing other than as permitted by Vermont law, unless you authorize us to make those disclosures.
California Residents Only: Under California law, we will not share information we collect about you with nonaffiliates unless the law allows. For example, we may share information with your consent, to service your accounts. We will limit sharing among our affiliates to the extent required by California law.