legal and privacy

Santa Clara Ventures and the Bronco Venture Fund are products and services of Vaulted Management Company, LLC, a venture capital firm that sponsors and manages venture capital funds. Past performance of any investment or fund is not indicative of future results. The funds are very long-term investments that involve substantial risk of loss, including loss of all capital invested.

VMC does not provide personalized advice about investments. The contents on this site and that available on any associated distribution platforms and any VMC-related social media accounts, platforms, and sites (“content outlets”) should not be construed as or relied on in any manner as investment or other advice. You should consult your own advisers as to legal, business, tax, and other related matters concerning any investment.

This website and all content outlets are for informational purposes only; offers of securities are made only to accredited investors pursuant to a fund’s offering documents, which describe the risks, fees and other information that should be considered before investing.

Examples of portfolio company investments are provided for illustrative purposes only; there is no guarantee that any fund will invest in or achieve the same exposure to, or quality of, companies held by any existing fund.

This Privacy Policy explains how Vaulted Management Company, a Delaware limited liability company and its subsidiaries and affiliates (“VMC,” “we,” or “us”), ”) collects, uses, and discloses information about you when you access or use our website and other online products and services (collectively, the “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services (like send a message through the Services), fill out an application, investor questionnaire, subscription agreement or another form, make an investment, apply for a job, communicate with us via third party social media sites (such as LinkedIn), request customer support, or otherwise communicate with us. The types of information we may collect when you access or use our Services as a non-investor include your contact information (name, email address, postal address, phone number) and educational information (post-secondary education level, post-secondary institution of attendance), as well as any other information you choose to provide. If you are an investor, we may collect the above-listed information in addition to other information including additional identifiers (such as your social security number), financial information (bank account and routing information, other payment information, wire transfer instructions, information in support of your accredited investor status, transaction history, other payment information, income sources, net worth, investment preferences), employment information (current and former employers, job titles, duration of employment), and any other information you choose to provide.

When you access or use our Services, transact business with us or engage with us at events, we automatically collect information about you, including:

• Usage Information: We collect information about your use of the Services as more fully described below.
• Transactional Information: When you make an investment, we collect information about the investment, such as fund details, investment vehicle, investment amount, and date of the investment.
• Log Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
• Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Location Information: We may derive the approximate location of your device from your IP address. In accordance with your device permissions, we may also collect information about the precise location of your device. You have the ability to stop the collection of precise location information at any time (see Your Choices below for details).
• Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us to: improve our Services and your experience, see which areas and features of our Services are popular, count visits, email you recommendations, and share data with advertisers so that the ads you see are more relevant to you. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Your Choices below.

We may also obtain information about you from other sources. For example, we may collect information about you from parties, including but not limited to identity verification services, credit bureaus, mailing list providers, publicly available sources, customer feedback, financial services providers, and marketing service providers. Additionally, if you create or log into your account through a social media site, such as LinkedIn, we will have access to certain information from that site, such as your name, account information, and friends lists, in accordance with the authorization procedures determined by such social media site.

We may derive information or draw inferences from you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address.

We use the information we collect for business and commercial purposes, such as to process your transactions, maintain your accounts, and provide you with tax-related information, and for our and our affiliates’ marketing purposes, such as to offer VMC-managed funds to you, notify you of and invite you to events, and customize your experience with us. We also use the information we collect to:

• Conduct credit checks and background checks, as applicable;
• Comply with corporate governance, audit, reporting and regulatory and legal requirements;
• Facilitate payment processing and investment account management;
• Provide, maintain and improve our products and services;
• Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
• Communicate with you about products, services, and events offered by VMC and others, and provide news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Personalize your online experience and the advertisements you see when you use the Services or third-party platforms based on your preferences, interests, and browsing and purchasing behavior and audit your interactions with our online ads, including by counting ad impressions and verifying positioning and quality of ad impressions;
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of VMC and others;
• Debug to identify and repair errors that impair existing intended functionality;
• For limited internal uses, provided the personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction;
• In connection with research and development activities; and
• Carry out any other purpose described to you at the time the information was collected.

We will not share data except in the following circumstances:

• With vendors, service providers, and consultants that perform services for us, including providers who assist us with operating and supporting the Services and with other investment processing functions, financial intuitions, such as your bank to fund your investments, third-party custodians including third-party IRA custodians if you choose to invest through an IRA, and our analytics, marketing and consulting service providers assisting us with the preparation and circulation of our business and marketing communications and event planning;
• With our affiliates, such as subsequently-formed VMC-managed funds, that may use eligibility information about you to make marketing solicitations; if you do not wish to receive solicitations, please email us at privacy@santaclaraventures.com to opt out;
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of VMC or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among VMC and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
• With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

The Services may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media, such as LinkedIn, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by VMC and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices and http://www.youronlinechoices.eu/.

VMC is based in the United States and we process and store information in the U.S. We and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.

You may update and correct certain account information you provide to us at any time by emailing us at privacy@santaclaraventures.com. Once you no longer invest with us, please note we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see Your Choices below.

You may opt out of receiving promotional emails or text messages from VMC by following the instructions in those emails or text messages or by emailing us at privacy@santaclaraventures.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83). This section applies only to California residents.

Additional Disclosures Related to the Collection, Use, and Disclosure of Personal Information

Collection and Use of Personal Information: We do not sell personal information. In the preceding 12 months, we have collected the following categories of personal information: identifiers, characteristics of protected classifications under California or federal law, commercial information, Internet or other electronic network activity information, professional or employment-related information, education information and inferences drawn from any of the information collected. For examples of the precise data points we collect and the sources of such collection, please see “Collection of Information” above. We collect personal information for the business and commercial purposes described in “Use of Information” above.

Disclosure of Personal Information: We may share your personal information with third parties as described in the “Sharing of Information” section above. In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: social security number, name, date of birth, postal address, email address, telephone number, bank account number, account user name and password, and online identifier (such as LinkedIn profile details).

Your Consumer Rights

If you are a California resident, you have the right to request (1) more information about the categories and specific pieces of personal information we have collected and disclosed for a business purpose in the last 12 months and (2) deletion of your personal information. You may make these requests by contacting your assigned VMC representative or emailing us at privacy@santaclaraventures.com. Please note we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time. If you are an investor, we will verify your request by asking you to provide information related to your recent interactions with us, such as information regarding a recent investment. If you have not invested with VMC, we will verify your request by asking you to confirm the details of your chosen communication method (such as your email address). To designate an authorized agent to exercise these rights on your behalf, please contact us using the details identified in the “Contact Us” section below. We will not discriminate against you if you exercise your rights under the CCPA.

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please contact us by emailing us at privacy@santaclaraventures.com.

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

When we process your personal data, we will only do so in the following situations:

• We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the investments or services you have requested).
• We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to our investments and Services, and to provide, secure, and improve our investment and Services.
• We find such processing is necessary to comply with our legal obligations.
• We have your consent to do so. When consent is the legal basis for our processing, you may withdraw such consent at any time.

You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may email us at privacy@santaclaraventures.com.

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your Data Protection Authority, please see:

http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, or for Swiss residents, see https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html.

If you have any questions about this Privacy Policy, please contact us at:

1671 Dell Ave, Suite 204

Campbell, CA 95008

privacy@santaclaraventures.com