PRIVACY POLICY

VENDOVENTURES WEBSITE PRIVACY POLICY

Effective January 1, 2025

This Privacy Policy (“Policy”) explains the privacy practices of VendoVentures Holdings SL (“VendoVentures,” “we,” “our,” or “us”). It applies to our processing of personal information that we collect through our website (www.vendoventures.com), our online or offline interactions with you, and to Personal Information that may be made available to us by our independently operated portfolio companies, or that we otherwise obtain in the course of our operations (collectively, our “Services”). Your use of our website signifies acceptance of the terms of this Policy and agreement to our Terms of Use.

If you are a VendoVentures investor or a representative of an investor, please see our Investor Privacy Notice, which is available in our investor portal, for additional information about our collection, use, and sharing practices with respect to investor information.

1. Personal Information We Collect
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

The Personal Information we collect about you may vary depending on the nature of your interactions with us. In general, we collect the following categories of Personal Information:

  • Identifiers and Personal Records, including name, alias, postal address, unique personal identifier, online identifier, IP address, email address, telephone number, account name, signature, social security number, driver’s license number, passport number or other similar identifiers, physical characteristics or description, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information. This category includes information described in Cal. Civ. Code 1798.80(e).

  • Characteristics of protected classifications, including age and date of birth, marital status, race, ancestry, ethnic origin, sex, gender, sexual orientation, gender identity, religion or creed, military or veteran status, medical condition, genetic information, disability, marital status

  • Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

  • Internet or other electronic network activity information, including browsing history, search history, and information regarding your interactions with our websites, applications, or advertisements

  • Audio, electronic, visual, thermal, olfactory, or similar information, including photographs and video, and audio recordings as may relate to job functions or interactions with VendoVentures via phone or videoconferencing

  • Geolocation Data, inferred from your IP address

  • Professional or employment-related information

  • Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your education

  • Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

  • Sensitive Personal Information, including the following categories of Sensitive Personal Information:

    • Personal Information that reveals a Social Security, driver’s license, state identification card, or passport number

    • Personal Information that reveals an 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

    • Personal Information that reveals racial or ethnic origin, national origin, citizenship or immigration status, religious or philosophical beliefs, or union membership

    • Personal Information collected and analyzed concerning health

    • Personal Information collected and analyzed concerning sexual orientation or gender identity

2. Sources from Which We Collect Personal Information
Generally, we collect the categories of Personal Information described above from the following categories of sources:

  • Directly from you

  • From our affiliates, subsidiaries, and portfolio companies

  • Through tracking technologies we use on our website

  • Within the context of due diligence for potential acquisitions

  • From service providers that help us to operate our business (e.g., vendors that provide communications, market research, analytics, customer support, and other services)

  • From internet service providers, data analytics providers, advertising networks, social networks, and third parties from which we may license or purchase data

  • Created by us (e.g., drawing inferences from the other categories of Personal Information we collect or assigning a username or email address to an employee)

3. Our Purposes for Collecting Personal Information
Generally, we use the Personal Information we collect for the following purposes. The specific purposes for which we collect your Personal Information may vary depending on the nature of your relationship with us.

  • To provide our Services

  • To communicate with you

  • To provide and improve our investment services, including evaluating potential investments and managing existing investments. (Please see our Investor Privacy Notice for additional information.)

  • To analyze trends and improve our Services

  • To provide analytics, financial analysis, data strategy, consultation on, development or improvement of products and services, marketing, advertising, and related services pursuant to agreements with our portfolio companies

  • For promotions, marketing, and events

  • For recruiting and employment purposes, including opening and maintaining application records, assessing eligibility for employment, onboarding employees, providing compensation and benefits, allowing you to perform your job functions, and managing our workforce.

  • To manage the security of our systems, property, website, and Services

  • To manage and support our IT resources and infrastructure

  • To comply with applicable laws and regulations

  • To detect, investigate, and protect against malicious, deceptive, fraudulent, or illegal activity

We may use the categories of Sensitive Personal Information we collect to comply with government reporting requirements and other legal obligations, for security and fraud-prevention, and for employee onboarding, benefits and accommodations.

In addition to the purposes described above, we may use and disclose any category of Personal Information or Sensitive Personal Information we collect to respond to law enforcement requests, or as otherwise required or authorized by applicable law, court order, or governmental regulations; to protect our rights and interests and those of others; to resolve any disputes; to enforce our terms and policies; and to evaluate or conduct a merger, sale, or other acquisition of some or all of our assets. We also reserve the right to use Personal Information we collect for any other purpose identified in an applicable privacy notice or agreement between you and us, or otherwise with your consent.

4. How Long We Keep Your Personal Information
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

  • Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;

  • Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;

  • The Personal Information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or

  • We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.

Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires.

At VendoVentures, we believe the best way to create value is to form a close partnership with outstanding operating executives and a value-added Board of Directors.