Privacy Policy
JANUARY 1, 2020
Versant Ventures knows your privacy is important to you, it is important to us too. This Privacy Policy explains the types of information that we may collect through http://www.versantventures.com/ (the “Site”) and how we may use, disclose and plan to protect such information once it is collected. As our firm and the venture capital industry evolve, this Privacy Policy may change, so please check this page periodically to ensure you are up to date with our current practices.
The Site is owned and operated by Versant Venture Management, LLC and its affiliates (referred to collectively in this Privacy Policy as “Versant,” “we,” “us,” “our” and other similar pronouns).
What information do we collect on the Site?
We may collect information from or about Site users concerning use of the Site.
We may collect Personal Data that you provide directly to us if and when you enter certain information on our Site. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
As is the case with many websites, our servers automatically collect your browser type and IP address when you visit the Site, and we may associate that with your domain name or that of your Internet access provider. In addition, we may capture certain “clickstream data” pertaining to your Site usage. Data captured may include, for example, the referring page that linked you to the Site, the country from which you are conducting your browsing session, the next website you visit when you leave the Site, and any search terms you have entered on the Site or a referral site. See our Cookies and Similar Technologies Notice in this Privacy Policy for more information about how the Site, related services and third party analytics, advertising and social media companies may use cookies and similar technologies to collect your information when you use the Site.
Sensitive personal information
Subject to the following paragraph, we ask that you not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or union membership) on or through the Site or otherwise.
If you send or disclose any sensitive personal information to us (such as when you submit user generated content to the Site), you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not provide it.
How do we use your information?
We may use your information:
• for other purposes disclosed when you submit information to us and in accordance with this Privacy Policy;
• provide improved administration of our Site;
• improve the quality of experience when you interact with our Site;
• send you administrative e-mail notifications, such as security, or support and maintenance advisories;
• respond to your inquiries related to employment opportunities or other requests;
To send you marketing communications:
If you request information from us we may send you Versant related marketing communications, which we believe may be of interest to you, as permitted by law but will provide you with the ability to opt out.
For security, compliance, fraud prevention and safety:
We may use your Personal Data as we believe appropriate to (a) investigate or prevent violation of the law or our Terms of Use; (b) secure the Site; (c) protect our, your or others’ rights, privacy, safety or property; (d) conduct fraud monitoring and prevention activities; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
For compliance with law; legal claims:
We may use your Personal Data as we believe appropriate (a) under applicable law, including laws outside your country of residence; (b) to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (c) where permitted by law in connection with a legal investigation; (d) to enforce our terms and conditions; (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; (f) to prosecute or defend legal claims; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
With your consent:
In some cases we may ask for your consent to collect, use or share your Personal Data, such as when you let us post your testimonials or endorsements on the Site. We may perform any of the above functions through our service providers.
Sharing with Third Parties
We generally do not share information collected about you through the Site. However, if we do collect Personal Data from you, we may, however, share your information (i) with third parties who provide services to us, (ii) as required by law and when we believe in good faith that disclosure is necessary to protect our rights or those of third parties, protect your safety or the safety of others, investigate fraud, or comply with a court order or other legal process, (iii) among our affiliates for our business purposes in accordance with this Privacy Policy, or (iv) in connection with a corporate change or dissolution, including a merger, sale of assets, reorganization, consolidation, bankruptcy, liquidation or wind down of business.
In addition, we may share non-personally identifiable Site usage information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information. The third parties that support our website analytics tools may be able to access and use your Site usage information.
Social Media
We maintain presence on several social media platforms, such as Twitter and LinkedIn, and we may also incorporate some third party social media features onto the Site. We may also include tools on the Site that allow you to share and/or publicly post content or information from the Site to your profile on a third party social media platform. Third party social media platforms have their own privacy policies which explain how they will use, protect and share your information, including any information you share on those platforms from the Site, and we encourage you to read them.
Your Access Rights
If you have an account hosted through an Access-Restricted Website, please refer to the privacy policies and practices of the operators of the Access-Restricted Website available on such Access-Restricted Website to understand your rights to review, update or modify certain of the information that is stored in that account.
Links to Third-Party Websites
Our Site may contain links or banners that lead to other websites, including investor portals, personal blogs, tweets, and other social media content written or edited by members of our staff, and these sites or entities may collect Personal Data from you. We have not control over, do not review, and are not responsible for these other sites or their content, and so their privacy policies (not this Privacy Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of such websites to understand how your information is treated. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
Information that you may provide, or that we may obtain, through your access to password-protected websites, such as an investor portal, that you may be able to access by following a hyperlink on the Site (each such other website, an “Access-Restricted Website”), is subject to the privacy policies and practices of the operators of the Access-Restricted Website available on such Access-Restricted Website, which we encourage you to read to learn about the treatment of such information.
International Data Use
Versant is headquartered in the United States and has affiliates and service providers in other countries, and your Personal Data may be collected, used and stored in the United States or other locations outside of your home country. Privacy laws in the locations where we handle your Personal Data may not be as protective as the privacy laws in your home country.
European Union users should read the important information provided in the Cross-Border Data Transfer section of this Privacy Policy about transfer of Personal Data outside of the European Economic Area.
Additional Information for European Union Users
Personal information
References to “Personal Data” or “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller and EU Representative
Versant is the controller of any of your Personal Data covered by this Privacy Policy for purposes of European data protection legislation and you can contact us using the contact details listed in the Contact Us section above. Our EU representative is Versant Ventures (Switzerland) GmbH.
Legal bases for processing
If we collect any of your Personal Data, we would only use it as permitted by law. We are required to inform you of the legal bases of our processing of your Personal Data, which are described in the table below. If you have questions about the legal basis of how we process your Personal Data, contact us at InvestorRelations@versantventures.com
Processing purpose (reference applicable section in this Privacy Policy for details) Legal basis
To provide the Service If you have entered a contract with us and we need to use your Personal Data to provide services you have requested or take steps that you request prior to providing services.
To send you marketing communications
To deliver you advertising
To create anonymous data
For security, compliance, fraud prevention and safety
To prosecute or defend legal claims These processing activities constitute our legitimate interests. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
For compliance with law Processing is necessary to comply with our legal obligations
With your consent Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the service or by contacting us at InvestorRelations@versantventures.com
Use for new purposes
If we collect your Personal Data, we may use your Personal Data for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention
We would only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Rights
European data protection laws give you certain rights regarding your Personal Data. You may ask us to take the following actions in relation to your Personal Data that we hold:
• Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing communications.
• Access. Provide you with information about our processing of your Personal Data and give you access to your Personal Data.
• Correct. Update or correct inaccuracies in your Personal Data.
• Delete. Delete your Personal Data.
• Transfer. Transfer a machine-readable copy of your Personal Data to you or a third party of your choice.
• Restrict. Restrict the processing of your Personal Data.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your Personal Data that impacts your rights.
If we collect your Personal Data, you can submit these requests by email to InvestorRelations@versantventures.com or our postal address provided above. 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. If you would like to submit a complaint about our use of your Personal Data or response to your requests regarding your Personal Data, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here (http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm).
We continually evaluate our data and systems for compliance with existing and emerging laws and regulations, including any obligations under the new California Consumer Privacy Act (CCPA). Please check back regularly as our website is updated from time to time. As noted below, if we make any significant changes, we may tell you about changes by additional means, such as by sending you an email. If you have any questions or concerns relating to the CCPA or otherwise, please contact us by email at investorRelations@versantventures.com or our postal address provided above.
A Note About Children
We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to us and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at InvestorRelations@versantventures.com.
Cross-Border Data Transfer
If we transfer your Personal Data out of the European Economic Area or Switzerland and are required to apply additional safeguards to your Personal Data under European data protection legislation, we will do so. Such safeguards may include applying the European Commission Model contracts for the transfer of personal data to third countries described here (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en#international-data-transfers-using-model-contracts), or for transfers to third parties in the United States, ensuring they participate in the EU-U.S. Privacy Shield Framework or Swiss-U.S. Privacy Shield Framework. Please contact us for further information about any such transfers or the specific safeguards applied.
Changes to this Privacy Policy
We may change this Privacy Policy from time to time. When we do, we will let you know by posting the changed Privacy Policy on this page. In some cases, for example, if we make any significant changes, we may tell you about changes by additional means, such as by sending you an e-mail. In some cases, we may request your consent to the changes. Any changes will be effective immediately upon posting to the Site.
Contact Us
We welcome your questions and comments about privacy. Please feel free to contact us by sending an e-mail to InvestorRelations@versantventures.com
Effective Date
January 1, 2020
Cookies and Similar Technologies Notice
Last Updated: September 10, 2018
Cookies are small data files stored in your browser by a website. They transmit information about your use of the site to its operator or to third parties that placed the cookie. Some cookies are “session cookies” that expire when you close your browser, and others are “persistent cookies” that stay on your computer or mobile device until you delete them.
Our sites and applications may use both session and persistent cookies to enable you to sign in and use our sites and applications, store your preferences and settings within them; analyze how they perform, personalize your experience with them, provide interest-based advertising, facilitate social media interaction and for other lawful purposes. We may also use other similar technologies for these purposes, such as web pixels that track browsing activity, social media widgets that facilitate interaction with social media platforms, unique device identifiers, and third party software embedded in our mobile applications. In some cases, these cookies and similar technologies are used by third parties.
The cookies and similar technologies used in our Site are as follows:
Type Description Third Party
Essential Essential to provide you with services available through our sites and to enable you to use some of their features.
We cannot provide the services our users request without them.
None
Functionality Allow our sites to remember the choices you make when you use our sites.
Intended to provide you with a more personal experience and to avoid you having to re-select your preferences every time you visit our sites.
None
Authentication Allow you to log into our sites and mobile apps by using your Google or Facebook account credentials. None
Analytics Collect information about traffic to our sites and mobile applications, and how our users use them, such as the number of visitors, the websites that referred them, the pages they visited, what time of day they visited, whether they have visited before, what features they used and other similar information. We use this information to help operate and improve our sites and mobile applications. None
Advertising Used by advertising companies to collect information about how you use our sites and mobile applications and other sites and applications over time. These companies use this information to show you ads they believe will be relevant to you within our sites and mobile applications and elsewhere, and to measure how the ads perform. None
Social Media Used by social media widgets that enable “like” buttons and allow you to share content within our sites and applications on social media. Your social media platform may be able to link information or actions about your interactions with our sites and applications to your account with them. Facebook
Twitter
Pinterest
Tumblr
LinkedIn
Please see your social media platform’s privacy policies for more details.
Disabling cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience on our sites. For example, you may not be able to store preferences in our sites. If you disable cookies, certain features of our website may not work.
For more information about targeting and advertising cookies and how you can opt out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu.
For more information about how we collect, use and share your personal information, see our Privacy Policy above.