Welcome to the website (including all websites to which this Privacy Policy is posted, the “Site”) operated by High Alpha Innovation, Inc. and its Affiliates (collectively “HAI,” “we,” “us,” or “our”). This Site provides, among other things, information about our people, organization and services, links to educational and informational content, and profiles of our portfolio companies, venture studios and venture funds (collectively, the “Services”).
This Privacy Policy explains what Personal Information we collect, how we use and disclose that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Use.
For deletion requests, please contact us at [email protected]. See Section 4 for additional information regarding changes to accounts generally as well as deletion of Personal Information (defined below).
For California residents (defined below), please see below for additional disclosures, our Notice at Collection and Use of Personal Information, and a description of your rights under the California Consumer Privacy Act (with any implementing regulations, as amended by the California Privacy Rights Act (“CPRA”), and as may be amended from time to time, “CCPA”).
Before using the Services or submitting any Personal Information to us, please review this Privacy Policy carefully and contact us if you have any questions. By using the Services, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Services.
1. PERSONAL INFORMATION WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Information”).
Personal Information You Provide. We may collect Personal Information when you visit our site, create an account, subscribe to our newsletter, sign up for an event, or communicate with us as follows:
- Event Information: If you attend one of our events you will be asked to provide Personal Information, including your name, the name and a description of your company or your fund, your contact information and other information that we will use to manage and administer your participation in our various events (“Event Information”).
- Communication Information: When you subscribe to our newsletter or otherwise communicate with us, we may collect your name, contact information, and the contents of any messages you send (“Communication Information”).
- Personal Information We Collect Through Our Social Media Pages: We have pages on social media sites like Instagram, Facebook, Twitter, YouTube and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details (“Social Information”). In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
- Personal Information We Receive Automatically From Your Use of the Site: When you visit, use, and interact with the Site, we may receive certain information about your visit, use, or interactions (“Technical Information”). For example, we may monitor the number of people that visit the Site, 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 Services (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, Technical Information includes the following, which is created and automatically logged in our systems:
- Log data: Log data is information that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
- Cookies: Please see the “Cookies” section below to learn more about how we use cookies.
- 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 Services, 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.
- Session replay information: Session replay information includes Device Information, broad geographical information, and the contents of your screen.
- Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
- Session Replay: We may use applications for session replay on SUS to help us analyze how users use the Site and to improve user experience.
- Analytics: Among other service providers, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
- Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
Your Choices. 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.
Advertising networks may use cookies to collect Personal Information: Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.
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 and administer access to the Services;
- To grant access to and track attendance at our events;
- To respond to your inquiries, comments, feedback, or questions;
- To send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies;
- To analyze how you interact with our Services;
- To maintain and improve the content and functionality of the Services;
- To develop new programs and services;
- To prevent fraud, criminal activity, or misuses of our Services, and to ensure the security of our IT systems, architecture, and networks;
- To ensure compliance with sanctions regulations; 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.
Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Services, to improve and add features to our Services, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy.
3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
In certain circumstances we may share your Personal Information with third parties without further notice to you, unless required by the law, as set forth below:
- 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, event management services, email communication software and email newsletter services, and web 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, 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 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 Services, or the public, or (v) protect against legal liability.
- Affiliates: We may share Personal Information with our Affiliates, meaning an entity that controls, is controlled by, or is under common control with HAI. Our Affiliates will use the Personal Information we share in a manner consistent with this Privacy Policy.
- With Your Consent. We may disclose your Personal Information to third parties upon your request, at your direction, or with your consent.
Other Users: certain actions you take may be visible to other users of the Services.
Please note that for purposes of this section, “sharing” does not include “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review California Privacy Rights below.
The following disclosures are intended to provide additional information about (1) the categories of Personal Information we collect, (2) the source of the Personal Information, (3) how we use each category of Personal Information, and (4) how we disclose Personal Information. These disclosures do not limit our ability to use or disclose information as described in Sections 2 and 3.
- Event Information: We collect Event Information directly from you. We use Event Information to grant access to, and administer your participation in, our events. We disclose Event Information to our Affiliates and the companies participating in and the vendors helping to host our events.
- Social Information We collect Social Information from you when you interact with our Social Media Pages. We use Social Information to perform analytics and to communicate with you. We disclose Social Information to our Affiliates.
- Communication Information We collect Communication Information directly from you. We use Communication Information for providing our Services and responding to you. We disclose Communication Information to our Affiliates and communication services providers.
Technical Information We collect Technical Information from you. We use Technical Information for analytics and in some cases, for moderation and prevention of fraud and malicious activity by users of our Services. We disclose Technical Information to our Affiliates and analytics providers.
4. YOUR CHOICES, DELETION REQUESTS, AND UPDATING YOUR INFORMATION
Your Rights and 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 Services, you may be unable to use those features. You can contact us at [email protected] to request to update, correct, or delete your Personal Information.
Deletion Requests: If you would like to request that we delete your Personal Information, contact us at [email protected].
5. CALIFORNIA PRIVACY RIGHTS
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your Personal Information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law. Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”
Notice at Collection and Use of Personal Information
Information We Collect. Depending on how you interact with us, we may collect the categories of personal information from or about you as identified in Personal Information We Collect and including:
- Identifiers and similar information, such as your name, address, date of birth, email address, online identifiers or other similar identifiers;
- Characteristics of Protected Classifications under certain federal or state laws, including gender, national origin, or marital status;
- Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing histories or tendencies;
- Audio, electronic, visual, or similar information;
- Geolocation information, such as information about your location or the location of your device;
- Professional or employment-related information, including occupation, compensation, employer, and title;
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99);
- Internet or other electronic network activity information, including interactions with our website or use of certain online tools, and IP addresses; and
- Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information.
Our Use and Collection of Information. We may collect and use Personal Information from you for the purposes described above in How We Use Information and described below in Our Collection, Use, and Disclosure of Personal Information.
Sale or Sharing of Personal Information. We do not sell or share your Personal Information (as those terms are defined under the CCPA).
How Long We Keep Information. How long we keep your Personal Information will vary depending on the type of personal data and our reasons for collecting it. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes) and our legal obligations (as laws or regulations may set a minimum period for which we have to keep your personal data). In general, we will retain your Personal Information for as long as we require it to fulfill the business purposes for which it was collected, perform our contractual rights and obligations, or for periods required by our legal and regulatory obligations.
For more information about our privacy practices, please review our entire Privacy Policy.
Our Collection, Use, and Disclosure of Personal Information
The following disclosures are intended to provide additional information about (1) the categories of Personal Information we have collected in the preceding 12 months (as listed in Information We Collect), (2) the source of the Personal Information, (3) the business or commercial purposes for our collection of the Personal Information and (4) how we may disclose Personal Information for a business purpose. These disclosures do not limit our ability to use or disclose information as described in Sections 2 and 3. We do not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California Residents under 16 years old.
- Identifiers and similar information: We collect this information directly from you. We use this information for operational purposes, including for logging you into your account and granting you access to the Services, to provide you with the Services, to enforce our community norms and policies, and to monitor the Site for security purposes. We disclose this information to our Affiliates, and in some cases, to service providers, HAI portfolio companies, studios and funds, and/or other users of the Services.
- Characteristics of Protected Classifications: We collect this information directly from you. We use this information as directed by you and in some cases, to compile and publish aggregated statistics. We disclose this information to our Affiliates, and in some cases, to HAI portfolio companies, studios and funds and/or other users of the Services.
- Commercial information: We collect this information from you directly from your interactions with the Services. We use this information to provide you with the Services and to improve the Services. We disclose this information to our Affiliates and analytics providers.
- Geolocation information: We collect this information directly from you through your interactions with the Services. We use this information for analytics purposes, regulatory compliance, and in some cases, for moderation and prevention of fraud and malicious activity by users of our Services. We disclose this information to our Affiliates and analytics providers.
- Professional or employment-related information: We collect this information directly from you. We use this information to provide you with the Services. We disclose this information to our Affiliates, and in some cases, to HAI portfolio companies, studios, funds, and/or other users of the Services.
- Education information We collect this information directly from you. We use this information to provide you with the Services. We disclose this information to our Affiliates, and in some cases, to HAI portfolio companies, studios and funds, and/or other users of the Services.
- Internet or other electronic network activity information: We collect this information directly from you through your interactions with the Services. We use this information to improve the Services, for analytics, and in some cases, for moderation and prevention of fraud and malicious activity by users of our Services. We disclose this information to our Affiliates and analytics providers.
Inferences drawn from any of the information identified above: We collect this information directly from you through your interactions with the Services. We use this information to improve and personalize the Services. We disclose this information to our Affiliates.
In addition, in the preceding 12 months, we may have disclosed all of the categories of Personal Information identified in Information We Collect above to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our Affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose the categories of Personal Information identified in Information We Collect for the business or commercial purposes identified above in How We Use Information. Additionally, we may disclose your Personal Information to third parties upon your request, at your direction, or with your consent.
We may also disclose your Personal Information or otherwise make it available to our service providers, other entities that have agreed to limitations on the use of your Personal Information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.
To the extent provided for by law and subject to applicable exceptions, California residents may have the following privacy rights in relation to the Personal Information we collect, including the right to:
- Be informed, at or before the point of collection, of the categories of Personal Information to be collected, and the purposes for which the categories of Personal Information shall be used;
- Know what Personal Information we have collected and how we have used and disclosed that Personal Information (“Request to Know”);
- Request deletion of your Personal Information, subject to certain exemptions (“Request to Delete”);
- Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your Personal Information (we do not);
- Opt-out of the “sharing” (as that term is defined in the CCPA) of your Personal Information if a business shares your Personal Information with third parties (we do not);
- Limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit);
- Correct inaccurate Personal Information (“Request to Correct”); and
- Be free from discrimination relating to the exercise of any of your privacy rights.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. We also reserve the right to retain, and not to delete, certain Personal Information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
Exercising Your Rights. California residents can exercise their right to Request to Know, Request to Correct or Request to Delete (“Consumer Rights Request”) as described above, through the following toll-free telephone number +1 (415) 874-1528 or by contacting us at [email protected].
Verification. In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a Consumer Rights Request. In verifying your request, we may ask you to provide additional Personal Information and proof of residency for verification. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only. If we cannot verify your identity, we will not provide, delete or correct your Personal Information.
Authorized Agents. You may submit a Consumer Rights Request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us.
Shine the Light Disclosures. California law requires us to inform California residents who have provided us with personal information that they may request information from us about our disclosures to third parties for their direct marketing purposes. To request this information, please contact us at [email protected]. In your request, please specify that this is a “California 'Shine the Light' Request.”
6. CHILDREN
Our Services are not directed to children who are under the age of 13. High Alpha Innovation does not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to High Alpha Innovation through the Service, please contact us at [email protected] and we will endeavor to delete that information from our databases.
7. LINKS TO OTHER WEBSITES
The Services may contain links to other websites not operated or controlled by High Alpha Innovation, including social media services (“Third Party Sites”). The information that you disclose to Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
8. SECURITY
You use the Services at your own risk. We implement commercially reasonable technical, administrative, and organizational measures designed 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 Services or email. Please keep this in mind when disclosing any Personal Information to High Alpha Innovation via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third party websites.
9. INTERNATIONAL USERS
By using our Services, you understand and acknowledge that your Personal Information will be transferred from your location to our facilities and servers in the United States.
10. CHANGES TO THE PRIVACY POLICY
The Services and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Services or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
11. QUESTIONS ABOUT THE PRIVACY POLICY
If you have any questions about our Privacy Policy or information practices or need to access this Privacy Policy in a different format, please feel free to contact the legal team at [email protected].