Last Updated: September 2023
137 Ventures Management, LLC (“137 Ventures”) is a leading provider of customized liquidity solutions to founders, investors, and early employees of growth-stage private technology companies. In addition to personalized liquidity solutions, 137 Ventures also participates in primary direct equity financing rounds. 137 Ventures, Management, LLC and its affiliates (“137 Ventures,” “we,” “our,” and/or “us”) value the privacy of individuals who use our website and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) covers the information we collect from you through our website or other online services and explain show we collect, use, and share information from or about 137 Ventures users (“Users”) or their devices. Please note that we may collect additional information from our investors outside of the website or online service –please refer to our financial information privacy notice for more information.
By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.
Information We Collect
We may collect a variety of information from or about you or your devices from various sources, as described below.
If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.
A. Information You Provide to Us.
Investor Portal Registration Information. If you sign up for an investor portal account on our Services, we ask you for your name, email address, and phone number.
Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our Investor RelationsTeam, we will receive your name, email address, phone number, company, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver abetter customer experience and improve our Services.
B. Information We Collect When You Use Our Services.
Location Information. When you use our Services, we may infer your general location information, for example, by using your internet protocol (IP)address.
Device Information. We may receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.
Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, investments you make, and the dates and times of your visits.
Information from Cookies and Similar Technologies. We and third party partners collect information using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and maybe used by your browser on subsequent visits to our Services.
Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
C. Information We Receive from Third Parties.
Third Parties and Affiliates. We may receive additional information about you, from affiliates and third parties and combine it with other information we have about you.
How We Use the Information We Collect:
How We Share the Information We Collect
We may share or otherwise disclose information we collect from or about you as described below or otherwise disclosed to you at the time of the collection.
Affiliates. We may share any information we receive with our corporate affiliates for any of the purposes described in this Privacy Policy.
Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
Marketing. We do not rent, sell, or share information about you with non affiliated companies for their direct marketing purposes, unless we have your permission.
Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.
Merger, Sale, or Other Asset Transfers. We may disclose and transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.
Consent. We may also disclose information from or about you or yourdevices with your permission.
Your Choices
Marketing Communications. You can unsubscribe from our promotional emails by responding to the emails with such requests. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
Please reference the privacy policies of Standish Management, LLC’s and Ark PES, Inc. if accessing the LP Login Portal at the links below.
https://www.standishmanagement.com/privacy-policy-3/
https://www.arkpes.com/privacy/
Security
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.
Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at compliance@137ventures.com.
International Visitors
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.
Pose a Question
If you have questions about your privacy on the Services or this privacy policy, please contact us at compliance@137ventures.com.
Changes to this Privacy Policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.
137 Ventures is responsible for processing your information. If you have any questions, comments, or concerns about our processing activities, please email us at compliance@137ventures.com or write to us at
137 Ventures Management LLC
233 Post Street, 6th Floor
San Francisco, CA 94108
United States