Privacy Policy

General

This Privacy Policy ("Policy") governs how Luvenire Capital Limited and its related entities (referred to collectively as "Luvenire Capital," "we," "us," or "our") gather and utilize your data when you visit our website located at https://www.luvenire.com/ (referred to as the "Site"). Unless specifically indicated otherwise, this Policy does not extend to websites, mobile apps, or digital platforms managed by our portfolio companies or third parties. Your use of this Site constitutes acceptance of the terms outlined in this Privacy Policy.

This document outlines what visitor data we gather from the Site, our purposes for collecting it, and the parties with whom we may share it. Additionally, we detail our security protocols for safeguarding your information and provide contact methods for privacy-related questions. Our Site is designed for general audiences and is not intended for individuals under 18 years old. We do not intentionally gather personal data from minors.

Categories of Personal Information We Collect

This Policy provides comprehensive details about the personal data we gather from our users. In compliance with the California Consumer Privacy Act (CCPA), we must disclose the "categories" of personal data we collect, which include: identifying information (including name, postal address, and email); online activity data (such as browsing patterns and service interactions); approximate location data (such as city and state derived from IP addresses, or precise coordinates when you provide consent); and additional data that can reasonably identify you or be linked to your identity.

What Information We Collect and the Sources of Such Information

Our data collection occurs through various channels during your Site visit. This includes information you voluntarily submit to us and data we automatically gather from your device or browser. We reserve the right to consolidate information obtained from these different sources to create a comprehensive profile.

Information You Provide Directly to Us

Any data you voluntarily share with us will be collected and stored. When you reach out to our team, we may gather details including your full name, email contact, company affiliation, telephone number, geographical location, and message content. For existing Luvenire Capital investors, additional documentation required for shareholder privileges (such as government-issued identifications or verification credentials) may be requested under a distinct privacy notice provided separately to you.

Information We Collect Through Automated Means

During your navigation of our Site, we employ automated technical systems to gather usage data.

Website Usage Information

While you interact with our Site, both we and our contracted service providers (third-party organizations assisting us in operating and improving the Site) deploy various tracking technologies, including cookies and related mechanisms, to monitor your usage patterns. Our server infrastructure automatically logs specific data points including web requests, IP addresses, browser specifications and configurations, entry and exit page URLs, click frequencies, link interactions, domain information, visited pages, mobile network operators, device identifiers, and timestamps, among other technical details.

Location Information

We gather and analyze general geographic data relating to the device you use to access our Site, such as estimated location derived from IP address analysis.

Cookies and Other Tracking Technologies

Together with our service partners, we utilize web server logs and digital tracking mechanisms such as cookies and tracking pixels to monitor Site activity. Server logs serve as repositories for website interaction data. Cookies are compact text files stored on your device during site visits, enabling us to: (a) identify your system; (b) track your page navigation history; (c) personalize content based on your apparent preferences; (d) conduct analytical assessments; and (e) maintain security protocols. Tracking pixels (also known as web beacons or transparent GIFs) function as minuscule electronic markers embedded in web pages and emails, capturing interaction metrics like click-through rates and cookie access. These beacons may appear in our email correspondence, newsletters, and digital communications to track message engagement and support analytics, customization, and promotional activities. As technological capabilities evolve, we may implement new collection methodologies. You retain control over cookie settings through your browser configuration, with options to receive notifications or block cookies entirely. Browser help resources (available in Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari, etc.) provide guidance on these settings. Be aware that restricting cookies may limit your access to certain Site functionalities.

How We Use the Information Collected

The data we gather from you may be utilized by us and our service partners for various objectives, including:

Fulfilling the specific intent for which you submitted the information;
Operating, sustaining, and enhancing the Site's functionality;
Identifying and resolving technical difficulties or security vulnerabilities;
Distributing informational materials or communications, including periodic newsletters;
Handling and responding to user questions or soliciting user input;
Recognizing your devices and linking multiple devices or browsers you employ to facilitate improved content delivery and operational efficiency;
Performing internal data analysis, research studies, and performance reporting;
Fulfilling legal obligations and safeguarding the wellbeing, rights, assets, or security of Luvenire Capital, our Site, and the broader public; and
Upholding the legal agreements governing your Site usage.

The personal data categories we collect may be applied toward legitimate business and commercial objectives (as legally defined), specifically:

Supporting operational functions for ourselves or our service contractors;
Reviewing and analyzing user engagement with our platform;
Identifying, preventing, and addressing security breaches, fraudulent activities, and unlawful conduct;
Identifying system errors and technical malfunctions;
Tailoring displayed content through our platforms or via service providers;
Additional applications including direct outreach to Site users;
Further purposes for which we provide advance notification.

Be advised that we retain the right to merge data collected directly from you (including through automated processes) with information sourced from our corporate affiliates, subsidiary entities, and unrelated third-party organizations, utilizing this consolidated information consistent with this Privacy Policy.

Information gathered via the Site may undergo aggregation or anonymization processes. Such processed data may be employed without restriction for research, analytical purposes, and may be distributed to various entities including business partners, affiliated companies, subsidiaries, service contractors, and other parties.

How and When We Share Information with Third Parties

When you submit personal data through our Investor Relations Inquiry form, you authorize us to distribute this information as described below. Mobile contact information will not be provided to external parties or affiliates for promotional marketing purposes. The personal data categories and specific information types mentioned previously may be disclosed or distributed under these circumstances:

Related Corporate Entities

Information collected may be distributed among companies within the Luvenire Capital corporate structure.

External Service Contractors

We may grant data access to carefully selected third-party organizations that utilize this information solely to deliver services on our behalf. These contractors support various operational areas including sales operations, marketing initiatives, content and feature delivery, data analytics, information storage, security management, fraud detection, and additional services.

Legal Compliance and Protection

We may reveal information we have gathered and retain about you when mandated by legal requirements or when we reasonably determine that disclosure is necessary for legal compliance, safeguarding our rights, assets, or security, or protecting our user community, the general public, or other involved parties.

Corporate Restructuring

Should we participate in corporate consolidations, acquisitions, ownership transfers, bankruptcy proceedings, reorganizations, asset sales, or related due diligence activities, we may transfer or sell the data outlined in this Policy as part of such transactions. Your data would continue to be governed by the provisions and assurances in this Policy unless and until the acquiring entity implements modifications. We will adhere to any additional legal constraints applicable to such data transfers.

Website Analytics and Do-Not-Track

Website Analytics

Our Site may incorporate third-party analytical services that employ cookies and comparable technologies to gather and evaluate usage patterns, conduct audits and research, generate reports, and enable specific Site features. Users who wish to opt out of Google Analytics tracking may download the Google Analytics Opt-out Browser Extension available here.

Notice Concerning Do Not Track

Do Not Track ("DNT") represents a privacy setting available in select web browsers. While we offer users various opt-out tools for controlling third-party data collection on our Site (as outlined above), we do not currently process or acknowledge browser-based DNT signals. Additional information about Do Not Track functionality can be found here.

Data Security

We implement appropriate administrative, technological, and physical protections to guard against unauthorized loss, misappropriation, or modification of your data. The strength of these protective measures correlates with the sensitivity level of the collected and stored information. Nevertheless, we cannot provide absolute assurances that these safeguards will prevent all unauthorized access attempts, usage, or disclosure of your information, as complete security for internet-based and electronic data transmission remains unattainable despite our diligent efforts.

Data Transfers

Our Site operations are based in the United States. Users accessing from the European Union or other international locations should understand that submitted information will be transferred to and processed in the United States. Your engagement with the Site, utilization of our Services, and provision of personal data constitutes your agreement to this international data transfer.

Data Retention

Your information will be retained for the duration required to achieve the objectives outlined in this Policy, or for the period mandated or authorized by applicable law. Data may remain in backup systems and business continuity archives for extended periods beyond active retention timeframes.

Your Rights and Choices

Subject to applicable law, you may have certain rights with respect to your personal information, including the rights to access, review, update, delete, and correct inaccuracies in your personal information. For instance:

For California Residents

California Privacy Law

If you are a California resident, California law requires us to provide you with some information regarding your rights with respect to your "personal information" (as defined in the California Consumer Privacy Act ("CCPA")). In this Policy, we describe the categories of personal information we collect, the sources and uses of such information and the entities to which we share such information.

California Data Access and Deletion Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information, such as to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
Provide access to and/or a copy of certain personal information we hold about you.
Delete certain personal information we have about you.
Provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. Additionally, we will take reasonable steps to verify your identity before responding to a request. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us through our Privacy Policy Inquiry form.

Notice of Right to Opt Out of Sale of Personal Information

The California Consumer Privacy Act ("CCPA") sets forth certain obligations for businesses that "sell" personal information (as sell is defined under CCPA and under current guidance). We do not engage in such activity and have not engaged in such activity in the past twelve months.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion or sale opt out rights.

Shine the Light Disclosure

The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

International Users

Some international users of our Website have certain legal rights to access certain information we hold about them and to request its deletion. For example, your local laws may permit you to request that we:

provide access to and/or a copy of certain information we have about you;
prevent the processing of your information for direct-marketing purposes;
update information which is out of date or incorrect;
delete certain information which we have about you;
restrict the way that we process and disclose certain of your information;
transfer your information to a third party provider of services; and
revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the "Contact Us" section below at any time.

Links to Affiliates, Subsidiaries, and Third-Party Sites, Apps, and Services

For user reference and convenience, our Site may contain hyperlinks directing to websites operated by Luvenire Capital affiliates, portfolio companies, or unaffiliated third-party organizations. These external entities maintain their own independent privacy policies and practices. We disclaim responsibility for the privacy standards and procedures of any sites, applications, or services not directly operated by Luvenire Capital.

Changes to Our Privacy Policy

We retain the authority to modify this Policy periodically to accommodate evolving legal frameworks, alterations in our data handling procedures, Site feature updates, or technological advancements. Updated versions will be published through the Site, and users are encouraged to review this Policy regularly. For substantial Policy modifications, we will fulfill applicable legal notification and consent obligations.

Contact Information

If you have any questions about this Privacy Policy, please contact us at privacy@luvenire.com.