[Cervin Ventures] and its subsidiaries (collectively “Cervin”, “us”, “our” or “we”) are committed to protecting your privacy and providing you with a positive experience on our website (www.cervin.com), social media accounts, platforms, apps, and additional sites (collectively, “Sites”) and while using our services.
This Privacy Policy only covers our privacy practices with respect to the collection, use, and disclosure of personal information obtained through our Sites and through the use of our services, and any related support (collectively, our “Services”).
Depending on where you are located and your interactions with our Services, the processing of your personal information or any information that can identify you (“Personal Information”) by Cervin, is subject to data protection and privacy laws including the California Consumer Privacy Act (the “CCPA”).
COLLECTION OF YOUR PERSONAL INFORMATION
The types of Personal Information that we collect depends on your interactions with our Sites and Services. We may collect Personal Information directly from you when you use our Sites and Services, or we may collect information indirectly from you through the platforms we use to run our Sites and Services. The types or categories of information we may collect from you include the following:
Information You Submit: information that you may submit to us can include: (1) your name, username, and password; (2) your contact information, such as your personal or work postal address, email address, and phone number; (3) your employment information including your employer’s name, title, work email, phone number, and other contact information; (4) information about your communications with us, including the Personal Information you provide to us in an email or in conversations with our employees and personnel; (5) your marketing information preferences, including any consents you provide; (6) your personal financial account information or business account information, including bank account numbers, investment accounts, investment portfolios, and billing and shipping addresses; (7) your demographic information such as your gender, race, ethnicity, veteran status, and age; and (8) employment application information including your employment history, employment status, education, and other background information in connection with an application for employment with Cervin.
Information Indirectly Submitted: we may automatically collect certain Personal Information from you to help us with providing our Services. For example, we may collect online identifiers such as internet protocol addresses when you access our Sites or use our Services, we may collect search queries such as search texts and browsing history, and the type of computer or device type you are using, your access time, and the webpage from which you are visiting or webpage(s) in which you accessed during your visit to our Sites.
Information We Collect from Third Parties: on occasion, we may receive Personal Information 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 service to your browser that are stored on your computer’s hard drive) to keep track of your use of our Services and our Sites, to validate your identity, to remember your password and preferences, to tailor our Services to your preferences and interests, and to improve the quality of our Sites and Services. Generally, you can set your browser to not accept cookies, giving you the opportunity to choose whether or not to accept the cookies. Please note that if you do set your browser to not accept cookies, our Sites and Services may not function properly on your browser.
Children’s Privacy Information: we do not knowingly collect Personal Information from children without appropriate parental or guardian consent. If you believe that we may have collected Personal Information from someone under the applicable age of consent in your country without proper consent, please let us know using the methods described in the “How to Contact Us” section and we will take appropriate measures to investigate and address the issue promptly.
USES OF YOUR PERSONAL INFORMATION
We may use your Personal Information for the purposes of operating our business, delivering, improving, and customizing our Sites, and selling our Services, sending marketing and other communications related to our business, and for other legitimate purposes permitted by applicable law.
Some of the ways we may use your Personal Information include:
GDPR Disclosure: If you are from the EU, our legal basis for collecting and using your Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests, and not overridden by your data protection interest or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you.
SHARING YOUR PERSONAL INFORMATION
We employ other companies and individuals to perform functions on our behalf, such as for analyzing data and providing certain Services. These third-party service providers have access to Personal Information needed to perform their functions, but we require that they do not use Personal Information for other purposes. Personal Information 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 Information 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 our 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); (5) as part of a corporate transaction with a successor or affiliate or in connected with any acquisition, merger or sale of assets; and (6) in aggregated, anonymized, or de-identified form which cannot reasonably used to identify you.
WE DO NOT SELL, RENT, OR TRADE PERSONAL INFORMATION COLLECTED THROUGH OUR SITES WITH THIRD PARTIES.
SECURITY OF YOUR PERSONAL INFORMATION
We implement physical, administrative, and technical safeguards designed to protect your Personal Information from unauthorized access, use, or disclosure. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosures. However, you should know that no company, including Cervin, can fully eliminate security risks associated with Personal Information. Further, the internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any Personal Information you provide to us.
RETENTION OF YOUR PERSONAL INFORMATION
We will retain your Personal Information as needed to fulfill the purposes for which it was collected. We will retain and use your Personal Information as necessary to comply with our business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements. When we have no ongoing legitimate business need to process your Personal Information, we will either delete it, anonymize it or securely store your Personal Information and isolate it from any further processing until deletion is possible.
CONTROLLING YOUR PERSONAL INFORMATION
Our marketing emails permit you to “opt-out” of or “unsubscribe” from receiving further marketing emails. Certain jurisdictions, for example the EU, provide their residents certain privacy rights under applicable law, including the right to object to or restrict the processing of Personal Information, to transfer Personal Information (data portability), or to request that we correct any inaccuracies or otherwise update your Personal Information. Please see section “GDPR Notice” for more information if you are an EU resident.
You may send us an e-mail at [admin (at) cervin (dot) com] to exercise your rights or contact us as further described below under the “How to Contact Us”, “CCPA Notice”, or “GDPR Notice” section. We will respond to such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil your request, we may need you to provide certain information to verify your identity.
CCPA NOTICE
This Privacy Policy is adopted in part to comply with the CCPA. Under the CCPA, users of the Sites and Services that are California residents have certain rights to access and delete [and opt-out of the sale of their Personal Information]. Under the CCPA, Californian users have specific rights regarding their Personal Information. If you are a user that resides in California, this section describes your CCPA rights and explains how to exercise those rights.
1. Right to Request Information About what Cervin has Collected
You may submit a “request to know” the Personal Information or specific categories and pieces of Personal Information that Cervin collects about you, and the business purposes for which Cervin collects such Personal Information. Please see section “How to Make Requests under the CCPA” for information on how to submit a request to know.
2. Right to Request Deletion of Personal Information
You have the right to request that Cervin delete any of your Personal Information that Cervin collected from you and retained, subject to certain exceptions. Once Cervin receives and confirms your verifiable request (see “How to Make Requests under the CCPA” below), Cervin will delete (and direct our service providers or third-parties to delete) your Personal Information from its records, unless an exception applies.
3. Cervin Does Not Sell Personal Information
HOW TO MAKE REQUESTS UNDER THE CCPA
If you are a California resident, you may make a request to exercise your “right to know” or “right to delete” [or “opt-out of sale”] your Personal Information. When you submit a request, Cervin will confirm receipt of your request within ten (10) days, and Cervin will get back to you with a personalized response within forty-five (45) days of receiving your request. The timeframe for Cervin to provide the required information may be extended once by an additional 45 days when reasonably necessary, provided you are given notice of the extension within the first 45-day period.
Only you, or someone legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. If you are someone who will need a legally authorized agent to make a consumer request on your behalf, Cervin will require (1) verification of both yours and your agent’s identity (valid government issued identification or proof identity acceptable to us at our sole discretion), and (2) sufficient proof of your agent’s power of attorney pursuant to California Probate Code sections 4000-4545.
You can make a request by contacting us at:
GDPR NOTICE
Cervin recognizes that it may make its Services and Sites available to residents of the EU. For this reason, this Privacy Policy is tailored to address all rights under the GDPR and protect the privacy rights of EU residents. In addition to all the rights mentioned so far in this Privacy Policy (with the exception of the CCPA), EU residents have the right to:
You may make a request by contacting us at:
REGULATORY CHANGES AND NOTICES
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 Cervin, to provide Privacy Policy notices to our clients. If you are a natural person who invests with us, that notice will govern how we use your Personal Information for the purposes specified in that notice.
CHANGES TO THIS PRIVACY POLICY
Cervin may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices. You should review this page periodically for any such changes. When we change the Privacy Policy in a material manner we will notify you through either e-mail or by posting a notice on relevant areas of our Sites. Any updated version of the Privacy Policy will be effective as of the date set forth therein. By continuing use of our Services or Sites after such updates have occurred, you are expressly agreeing to the terms of the updated Privacy Policy.
HOW TO CONTACT US
If you have any questions about this Privacy Policy or our privacy practices, please contact us at info@cervin.com. You may also write to us at: Cervin Ventures, 820 Ramona Street, Unit 200, Palo Alto, CA.
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