OUR COMMITMENT TO PRIVACY
Visitors that are residents of California should refer to our California Website Privacy Policy supplement below.
Visitors that are residents of the United Kingdom, the European Union or the European Economic Area should refer to our EU and UK Website Privacy Policy below.
Your privacy is important to Curewell Capital Mangement LLC and its affiliates (together, “Curewell Capital,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information explaining our online information practices.
This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use information for visitors of this website. Please read this Privacy Policy carefully. If you do not agree with any of the terms and conditions contained herein, please do not access or otherwise use this website.
This Privacy Policy constitutes a legally binding agreement between Curewell Capital and you, the user of this website. By entering and using this website, you acknowledge your acceptance of, and agree to be bound by, the Privacy Policy stated herein, our Terms of Use and all additional terms incorporated by reference herein. If you do not agree to this Privacy Policy, please do not access or use this website.
THE INFORMATION WE COLLECT AND HOW WE USE IT
We may collect various types of information from users of this website. For example, knowing how users use our website – tracking their movement through this website – helps us improve website design and usefulness. As a result, Curewell Capital’s server collects general data pertaining to users, including the length of time spent on this website, the pages accessed while visiting the website and Internet Protocol (IP) addresses. Curewell Capital generally does not, however, collect any personally identifiable information such as names, home addresses or e-mail addresses from users of this website, unless a user submits such information to us via our “Contact” page or otherwise through the website, or through electronic communications (e.g., email) with Curewell Capital personnel.
To the extent that you provide us with any personally identifiable information through or in connection with this website, we may use such information for Curewell Capital’s business purposes, but will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to service providers. In providing personally identifiable information to Curewell Capital, you consent to Curewell Capital’s use of such personally identifiable information for the purposes described in this Privacy Policy. We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website; any transmission of information or data by you to or through this website is at your sole risk.
CAPACITY
You represent to Curewell Capital that you have the authority to visit this website according to the Terms of Use. This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
COOKIES
Information regarding how you access this website (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
You may access any personally identifiable information we have about you by contacting info@curewellcapital.com.
NOTIFICATION OF CHANGES
We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review our Privacy Policy regularly. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of the Privacy Policy under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Policy means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.
MISCELLANEOUS
The provisions in our Terms of Use are hereby incorporated by reference.
CONTACT US
If you have any questions or concerns about this Privacy Policy, please contact us at info@curewellcapital.com.
Last Updated: September 2023
This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
What does this Website Privacy Policy apply to?
This California Website Privacy Policy applies solely to (i) your interactions with us through our Website (as defined below) and (ii) if you are seeking employment with us. If you provide personal information to use through another means (e.g., as an investor) you will receive a separate privacy notice and that notice will govern that personal information.
What information do we collect about you?
We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
Category | Examples | Collected |
---|---|---|
A. Identifiers | Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | YES |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). | YES |
C. Protected classification characteristics under California or federal law | Date of birth, citizenship and birthplace. | NO |
D. Commercial information | Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). | NO |
E. Biometric information | Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. | NO |
F. Internet or other similar network activity | Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries. | YES |
G. Geolocation data | Physical location or movements. | NO |
H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
I. Professional or employment-related information | Current or past job history or performance evaluations. | NO |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
L. Sensitive Personal Information (see further information on use of sensitive personal information below) | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. | YES |
We do not knowingly collect or solicit personal information from anyone under the age of 18.
We do not collect or use sensitive personal information other than:
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
How do we use your personal information?
We will use your personal information for one or more of the following business or commercial purposes:
Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.
We retain the categories of personal information set forth above in “What information do we collect about you?” section of this California Website Policy only as long as is reasonably necessary for those purposes set forth above in “How do we use your personal information?”, except as may be required under applicable law, court order or government regulations.
Who do we disclose your personal information with?
We do not share (i.e., disclose to a third party for the purpose of cross-context behavioral advertising) or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected in connection with this Website for a business purpose to the categories of third parties indicated in the chart below. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Personal Information Category | Category of Third-Party Recipients |
---|---|
A. Identifiers | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
C. Protected classification characteristics under California or federal law | N/A |
D. Commercial information | N/A |
E. Biometric information | N/A |
F. Internet or other similar network activity | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
G. Geolocation data | N/A |
H. Sensory data | N/A |
I. Professional or employment-related information | N/A |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | N/A |
K. Inferences drawn from other personal information | N/A |
L. Sensitive Personal Information | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
How do we keep your personal information secure?
We consider the protection of personal information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection, use, disclosure and sale of personal information specific to you. Such information includes:
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
Contact us
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above. If we request you verify your request and we do not receive your response, we will pause processing your request until such verification is received.
Please contact us at info@curewellcapital.com with any questions about this California Website Privacy Policy.
Last Updated: September 2023
OUR COMMITMENT TO PRIVACY (EU AND UK)
Your privacy is important to Curewell Capital Management LLC and its affiliates (together, “Curewell Capital,” “our,” “us,” “we” or “company”). To better protect your privacy, we are providing information to explain our personal data handling practices.
This EU and UK Website Privacy Policy describes how we gather and use personal data that we collect:
This EU and UK Website Privacy Policy does not apply to any processing of personal data by or on behalf of Curewell Capital that is covered by a more specific privacy notice (including, without limitation, the Limited Partner Privacy Notice), and only applies to the extent EU and UK data protection laws (the “EU and UK Privacy Laws”), including Regulation (EU) 2016/679 (the “EU GDPR”), the UK equivalent of the EU GDPR (the “UK GDPR”) and the Data Protection Act 2018, apply to such processing. Please read this EU and UK Website Privacy Policy carefully.
For the purposes of applicable EU and UK Privacy Laws, Curewell Capital and its affiliated general partners and managing members will each be a controller of any personal data collected by us when you interact with us in the ways described above (e.g., when you visit our website, etc.). If you have any questions regarding our use of your personal data, or this EU and UK Website Privacy Policy, please contact info@curewellcapital.com.
We rely on various legal bases under the EU and UK Privacy Laws in order to process your personal data (e.g., name, email, IP address, financial data, etc.), including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Further information about the legal bases under which we process your personal data is included in the section headed “Why we use your personal data.”
You do not need to take any action as a result of this EU and UK Website Privacy Policy, but you do have certain rights as described below in the section headed “Your rights.”
HOW WE OBTAIN YOUR PERSONAL DATA
Information you provide to us
We collect your personal data when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal data via online form, email, post, telephone and this website. We also collect information about you through automated technology when you access and use our website, such as cookies and similar technology.
Information provided by third parties or publicly available sources
We collect personal data from third parties, such as background information from a background check provider, personal data we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions.
If you represent or work for one of our portfolio companies, we may also collect your personal data (i.e., basic identifying and contact information, including your [name, title, work email address, work postal address, job title and/or work telephone number], as appropriate) from the entity that you work for where this is necessary to conduct business, or manage our relationship, with such third party.
We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. In this situation, your personal data will be provided to us by third parties involved in that potential transaction (including the target of any investment).
WHY WE USE YOUR PERSONAL DATA
To the extent that you provide us with any personal data, or we otherwise collect your personal data (i.e., through or in connection with this website, our current and future portfolio companies and other data collection points) or the investor portal, we may use such information for the following purposes:
Purpose | Legal Basis |
---|---|
To conduct businesswith you or provide you with the services you have requested. | Contractual necessity; and/or our legitimate interest in operating our business and providing investment services. |
To communicate with you. | Our legitimate interest in operating our business and providing investment services. |
To keep a record of your relationship with us. | Our legitimate interest in operating our business and providing investment services; and/or legal requirement. |
To verify your identity (including to conduct anti-money laundering checks and to enable you to access our offices). | Legal requirement; and/or our legitimate interest in operating our business and providing investment services securely. |
To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to. | Our legitimate interest in operating our business and providing investment services; contractual necessity; and/or legal requirement. |
To protect against, identify and prevent, fraud, money-laundering, cyber attacks, theft of our property and other unlawful activity. | Legal requirement; our legitimate interest in operating our business and providing investment services securely. |
Litigation management and conducting internal audits and investigations. | Legal requirement; our legitimate interest in operating our business. |
To obtain advice from our professional advisors, including financial advisers and lawyers. | Our legitimate interests in operating our business. |
To administer and protect our business and this website. | Our legitimate interest in operating our business. |
To make suggestions and recommendations to you, or to provide you with updates or other information, about our business and services that may be of interest to you. | Our legitimate interest in operating our business. |
Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.
No solely automated decision-making, including profiling, is used when processing your personal data.
DISCLOSURE AND TRANSFER OF PERSONAL DATA
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this website; any transmission of information or data by you to or through this website is at your sole risk.
Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including legal and financial professional advisors, our auditors, consultants, administrators, placement agents, IT and data security providers and/or data hosting providers. We seek assurances that our standards for data security are met by anyone who enters into an agreement providing a service to, or for us. To the extent your personal data is transferred to countries outside of the UK or the European Economic Area, such transfers will only be made in accordance with the EU and UK Privacy Laws. For further information about the safeguards/derogations used, please contact us at info@curewellcapital.com.
We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal data to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL DATA
We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate data security technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access, disclosure, improper use, and accidental loss. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality and required to keep your personal data secure.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this EU and UK Website Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact us at info@curewellcapital.com.
CAPACITY
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal data from anyone under the age of 18 without parental consent. If we learn we have collected or received personal data from an individual under the age of 18, we will delete that information.
COOKIES
Information regarding how you access this website (e.g., browser type, access times and Internet Protocol (IP) address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes. Where cookies are not necessary for us to provide the products or services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used, and how you manage your cookie preferences.
You may refuse to accept cookies by altering the settings on your internet browser. For more information about how to do this, look at your browser ‘help’ section or visit www.allaboutcookies.org and www.youronlinechoices.eu. You can also opt out of using Google Analytics cookies here http://tools.google.com/dlpage/gaoptout. Please note that if you adjust your internet browser settings to refuse the setting of cookies, you may not be able to access or use fully certain parts or functionality of the website.
YOUR RIGHTS
You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact us at info@curewellcapital.com.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
NOTIFICATION OF CHANGES
We reserve the right to amend this EU and UK Website Privacy Policy from time to time by updating this EU and UK Website Privacy Policy. If we decide to change our EU Website Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with this EU and UK Website Privacy Policy under which the information was collected.
CONTACT US
If you have any questions or concerns about this EU and UK Website Privacy Policy, please contact us at info@curewellcapital.com.
COMPLAINTS
Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us. In the EU, this is the local supervisory authority in the EU Member State of your habitual residence, place of work, or place of the infringement, concern or complaint.