Introduction

This Privacy Notice describes how Sydecar, Inc. (“Sydecar”, “we”, “us”, and/or “our”) handles personal information we collect from or about you when you visit our websites; use the Sydecar platform or other services provided through our websites, including those at www.sydecar.io (collectively, our "Website"); when you interact with content, emails, messages, texts and other communications sent by us or users of our Website; or otherwise engage with us (collectively, our “Services”). This Privacy Notice also describes certain legal rights you may have, subject to applicable law, and how you can exercise them.

Please read this notice carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our practices, do not use our Services This notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the notice periodically for updates.

Children Under the Age of 18

Our Services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@sydecar.io.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website and other Services ("personal information"), including information:

• By which you may be personally identified, such as name, user name, home address, work address, gender, e-mail address, marital status, telephone number, social security number, tax ID number, employer ID number, government ID number, passport information, picture, billing address, professional history, copies of identification forms, money transfer instructions, funds transfer accounts, investment documents, credit reports and history, and other identifiers by which you may be contacted online or offline;

• Financial information such as bank account information, financial objectives, transaction history, salary, investment documents, financial statements, assets, investments, estate planning information, and ownership and control affiliations and relationships; and/or

• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us, either electronically or in person.

• From third parties, for example, our business partners.

• Automatically as you navigate through the Website or interact with our email communications. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

The information we collect may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our Services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Website.

• Information contained in documents that you upload to us such as deal updates, PPMs, etc.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Your responses to surveys that we might ask you to complete for research purposes.

• Details of transactions you carry out through our Website.

• Information you provide to us in person.

You also may provide information to be published or displayed (hereinafter, "posted") on the Website, or transmitted to other users of the Website or third parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

From Third Parties

We obtain information from third parties that we work with or engage in connection with our Services, including partners such as banks and payment processors, background verification services, credit reporting agencies, government databases, identity verification services, and third parties that may assist with the assessment of your eligibility or suitability to participate in certain opportunities or services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website or interact with content sent to you by us or other users of our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information that tracks when and how you interact with content sent by us and by other users of the Website;

• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See Your Rights and Choices below for information on how you can opt out of behavioral tracking on the Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Provide services to you through the platform offered through the Website.

• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser or setting your preferences through our cookie consent banner. However, if you decline cookies, you may be unable to access certain parts of our Website. 

• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Your Rights and Choices below.

• Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use and disclose information that we collect about you or that you provide to us, including any personal information:

• To present, develop, improve, maintain and deliver our Website and its contents and services to you.

• To provide you with the fund formation, special purpose vehicle, fund management and other services provided through the Website.

• To allow fund sponsors, investment leads and other investors to discover and communicate with potentially qualified investors.

• To allow users of the Website to communicate with each other.

• To allow users of the Website to track how, when and by whom content sent from the Website is interacted with.

• To determine your eligibility or suitability for various services and opportunities.

• To provide you with information, products, or services that you request from us or that we believe may be of interest to you.

• To provide you with notices about your account.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

• To notify you about changes to our Website or any products or services we offer or provide though it.

• To comply with regulations requiring us to identify our users and customers and related parties to regulatory, oversight, government, industry or compliance bodies.

• To make and file tax and other compliance reports.

• In any other way we may describe when you provide the information.

• For any other purpose with your consent.

Artificial Intelligence and Machine Learning

We may use artificial intelligence (AI) and machine learning (ML) technologies to enhance our products and services. This can include the use of personal information, including information collected through your use of our services, to develop, improve, and train: 

• AI/ML models that we have created internally; or

• Licensed third-party AI/ML models that we fine-tune for our business purposes. 

We do not allow third-party providers or licensors of AI/ML models to use your personal information to train, develop, or improve their own models or to benefit other customers. 

We do not use AI/ML technologies to make automated decisions that produce legal or similarly significant effects about you. If consent is legally required – such as for processing sensitive personal information – we will obtain it.

We use a mix of technical and organizational safeguards to ensure that data used in AI/ML training is limited to what is necessary, anonymized or pseudonymized where possible, and handled in compliance with applicable laws. 

Depending on your location, you may have rights related to the use of your personal information in AI/ML training, such as opting out or requesting deletion where feasible. For more information, please refer to the Your Rights and Choices section of this Privacy Notice.  

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose your personal information:

• To our subsidiaries and affiliates.

• To other users of the Website – such as deal organizers – who have invited you to the Website or initiated contact with you, and where we have collected your information (such as KYC details) in connection with that relationship. We may share such information with those users upon their request. 

• To users of the Website that send links or other content from the Website to you.

• To other users of the Website that you interact with on the Website, such as fund sponsors, investment leads, and other users and investors, and employees, agents, directors, representatives, and affiliates of such persons, including administrators, attorneys, advisors, accountants, and other third-party service providers.

• To third parties that you invite to access the Website, such as investment advisors, accountants, attorneys, administrators, and tax advisors.

• To auditors, accountants, certification providers, and other financial, accounting, security, and process auditing, attestation and certification groups.

• To contractors, service providers, and other third parties, including data centers, website application developers, hosting providers, maintenance services providers, backup services, storage application and facility providers, infrastructure providers, investment advisors, investment management services providers, software licensors, database providers, data security providers, privacy services providers, financial institutions, banking partners, credit reporting agencies, verification services, background and screening services, compliance review services, legal and accounting service providers, insurers and brokers, payment processors, and other third parties we use to support our business and the services we provide to you and our other customers.

• To international, state, federal, and local governments, quasi-governmental bodies, self-regulatory agencies, industry oversight, regulatory and governance bodies, tax and revenue agencies, securities regulatory agencies, professional groups and associations, corporate oversight regulators, securities regulators, banking regulators and other regulators.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Sydecar’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Sydecar is among the assets transferred.

• To fulfill the purpose for which you provide it.

• For any other purpose disclosed by us when you provide the information.

• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of use (See our Terms of Service) and other agreements.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Sydecar, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, credit risk reduction and increased security.

Additional Disclosures for California Residents

This Section applies solely to all visitors, users, and others who reside in the United States ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice

This Notice does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("CA Personal Information"). CA Personal Information does not include:

• Publicly available information from government records.

• Deidentified or aggregated consumer information.

• Information excluded from the CCPA's scope, like:

  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;

  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of CA Personal Information from consumers within the last twelve (12) months:

We obtain, use, disclose and share the categories of CA Personal Information listed above as described elsewhere in this policy.

Sharing CA Personal Information

In the preceding twelve (12) months, Sydecar has disclosed CA Personal Information for a business purpose to the categories of third parties indicated in the chart below.

For more on your CA Personal Information sale rights, see Right to Opt Out of Selling and Sharing below. 

Your Rights and Choices 

You have a variety of rights and choices regarding the personal information you provide to us:

• Restricting Tracking Technologies and Advertising. 

  • Browser/Flash Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly. 

  • Do Not Track (DNT): Sydecar does not currently change its behavior in response to web browser “do not track” signals. In the event that a universally accepted standard emerges on how organizations should respond to “do not track” signals, we will assess and provide an appropriate response to those signals. 

  • Global Privacy Control (GPC): GPC is a browser-based option that you can use to signal your privacy preference. Certain browsers and extensions will allow you to enable GPC. If you enable GPC, our cookie tool will automatically turn off al targeting cookies on our Website in response to your signal. You can learn more at: https://globalprivacycontrol.org/
    
    
    

• Opting Out of Promotional Messages from Sydecar. Sydecar may send you electronic direct marketing subject to national law, unless you have declined such messages. If you do not wish to receive such messages any longer, you can opt -out at any time by following the instructions in those messages or by contacting us as privacy@sydecar.io. Please be aware that it may take up to ten (10) days for us to process your request, and you may continue receiving promotional communications form us during that period. If you opt out of receiving such communications, please be aware that we may continue to send you non-promotional emails (such as emails related to our business relationship or emails about changes to our legal terms). 

• Accessing and Correcting Your Information. If you are already a registered user of our Services, you can review and change your personal information by logging into the Website and visiting your account profile page. You may also send us an email at privacy@sydecar.io to request access to, correct or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Please note that we may also keep certain personal information as necessary to comply with our legal obligations or for legitimate business purposes, such as to resolve disputes or enforce our agreements.

Rights and Choices under U.S. State Privacy Laws

Certain U.S. state privacy laws provide their residents with specific rights regarding their personal information. This section describes rights you may have (depending on where you live) and explains how to exercise those rights.

Right to Know and Data Portability

You may have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"), in a portable, and to the extent technically feasible, readily usable format. Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Correct, or Delete below), we will disclose to you:

• The categories of personal information we collected about you.

• The categories of sources for the personal information we collected about you.

• Our business or commercial purpose for collecting or selling that personal information.

• The categories of third parties with whom we share that personal information.

• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  • sales, identifying the personal information categories that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Correct

You have the right to request that we correct any incomplete or inaccurate information we hold about you. 

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know, Correct, or Delete above), we will review your request to see if an exception allowing us to retain the information applies. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to a legally permitted exception from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know, Correct, or Delete

To exercise your rights to know, correct, or delete described above, please submit a request by:

• Emailing us at privacy@sydecar.io.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

We may not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

Right to Opt Out of Selling and Sharing

Certain U.S. state privacy laws require that we disclose whether we sell or share your personal information. We do not sell personal data to third parties in exchange for money. However, we may engage in routine practices involving disclosing your personal information (in the form of identifiers and internet activity information) with third party advertising and analytics partners. These disclosures may qualify as a “sale” or “sharing” of personal information under certain U.S. state privacy laws. 

We do not sell or share mobile phone numbers, text message consent information, or communications data with third parties. Mobile information collected to facilitate voice or text interactions through our communications service providers (such as Dialpad) is used solely to provide those services on our behalf. Our service providers are not permitted to use this information for their own marketing purposes, other independent uses, or for the benefit of their other customers.
You have the right to direct Sydecar not to sell or share your personal information. You can exercise this right by emailing us at privacy@sydecar.io or by using the Global Privacy Control (GPC). You can also adjust your cookie preferences to decline all non-essential cookies on our Website. If you notify us of your preference through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal. If you are logged in, your preference will be associated with your account and if you log in from another device or browser, you will be automatically opted out. However, if you are not logged into your account, your request will only be associated with the browser you are currently using. 

Right to Opt Out of Targeted Advertising

If you are certain jurisdictions, you have the right to opt out of targeted advertising based on your personal information obtained from your activities over time and across websites or applications. 

Right to Limit the Use and Disclosure of Sensitive Personal Information

If you live in certain states, you have the right to request that we limit the use and disclosure of your sensitive personal information, such as your social security number, driver’s license number, state identification card, passport number and financial data, to certain purposes permitted by law. If you wish to exercise this right, please contact us at privacy@sydecar.io. 

Right to Opt Out of Processing for Purposes of Profiling

You may have the right to opt-out of processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects. Sydecar does not use your personal information for purposes of profiling. 

Response Timing and Format

We will confirm receipt of your request and provide our response within the time period stated by applicable law. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If we deny (or otherwise refuse to act) on your request to exercise your rights, we will provide you with information about how you can appeal our decision. 

Non-Discrimination

We will not discriminate against you for exercising any of your rights. This means that, unless otherwise permitted by law, we will not:

• Deny you goods or services.

• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

• Provide you a different level or quality of goods or services.

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by law that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@sydecar.io.

EU Data Rights

The information provided in this section applies only to individuals in the European Economic Area, United Kingdom and Switzerland (collectively, “Europe”) and explains our practices regarding personal information that we collect from you or which we have obtained about you from a third party and the legal basis for processing for your personal information. It also sets out your rights in respect of our processing of your personal information.

EU Personal Information. References to “EU Personal Information” in this EU Data Rights section are equivalent to “personal data” governed by the General Data Protection Regulation (GDPR).

Controller or Processor. We may be either the controller or processor of your EU Personal Information covered by this Privacy Notice, as stated under the heading “Information We Get From Others”.

Legal basis for processing.  The legal bases of our processing of your EU Personal Information will depend on the type of EU Personal Information and the specific context in which we process it.  However, the legal bases we typically rely on are set out in the table below.  We use your EU Personal Information only as permitted by law.

| Processing Purpose

Use for new purposes. We may use your EU Personal Information for reasons not described in this Privacy Notice where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and provide the applicable legal basis.

Sensitive personal information. If you provide us with any sensitive EU Personal Information to us when you use the Website, you must consent to our processing and use of such sensitive EU Personal Information in accordance with this Privacy Notice. If you do not consent to our processing and use of such sensitive EU Personal Information, you must not submit such sensitive EU Personal Information to us.

Your rights. You have the following rights in relation to the EU Personal Information we hold about you:

• Right of access: You can ask us if we are processing your EU Personal Information and to provide you with a copy of it (along with certain details). If you require additional copies, we may need to charge a reasonable fee.

• Right to rectification: If the EU Personal Information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified.

• Right to erasure: You can ask us to delete or remove your EU Personal Information in some circumstances such as where we no longer need it or if you withdraw your consent to our processing of your EU Personal Information (where applicable).

• Right to restrict processing: You can ask us to “block” or suppress the processing of your EU Personal Information in certain circumstances, such as where you contest the accuracy of that EU Personal Information.

• Right to data portability: You have the right, in certain circumstances, to obtain EU Personal Information you have provided us with (in a structured, commonly used and machine-readable format) and to re-use it elsewhere or to ask us to transfer this to a third party of your choice.

• Right to object: You can ask us to stop processing your EU Personal Information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your EU Personal Information, unless we can demonstrate compelling legal grounds for the processing; or

  • processing your EU Personal Information for direct marketing purposes.

• Right to withdraw consent: If we rely on your consent (or explicit consent) as our legal basis for processing your EU Personal Information, you have the right to withdraw that consent at any time.

• Right to lodge a complaint with the supervisory authority: If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, you can report it to the relevant Supervisory Authority.

You may submit these requests by email to privacy@sydecar.io. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Cross-border data transfer. If we transfer your EU Personal Information out of Europe to a country not deemed to provide an adequate level of personal information protection for purposes of applicable data protection laws such that additional safeguards are required, the transfer will be performed:

• pursuant to the recipient’s compliance with Standard Contractual Clauses;

• pursuant to the consent of the individual to whom the EU Personal Information pertains; or

• as otherwise permitted by applicable laws.

You may contact us if you want further information on the specific mechanism used by us when transferring your EU Personal Information out of Europe.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on secure servers behind firewalls. Any personal information, including any financial transactions, will be encrypted either by us or by our privacy security provider Very Good Security, Inc ("VGS"). We have retained VGS, a third-party privacy security provider, to securely store your financial and certain non-public personal information. Our access to information stored with VGS is limited to display-only and never stored locally.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not 100% secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Notice

It is our policy to post any changes we make to our privacy notice on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. The date the privacy notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy notice to check for any changes.

Contact Information

To ask questions or comment about this privacy notice and our privacy practices, contact us at:

2322 Bissonnet St, Suite 4, Houston, TX 77005 Email: privacy@sydecar.io