Last Updated: December 8, 2021
1.1 — Modern Ventures I LLC dba Cold Start (“Cold Start”) with its registered office at 16192 Coastal Highway, Lewes DE 19958 collects and uses certain Personal Data. Cold Start is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Cold Start (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Cold Start or any other person in respect of an individual.
2. The products and services we provide
Information we receive through our websites ("Cold Start Websites"); and
Information we receive through or in connection with the provision of our products and services ("Services").
3. The types of personal data we collect
3.1 — Many of the services offered by Cold Start require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:
Information that you provide to Cold Start. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):
Basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country).
Any information that you choose to share with us (whether through our websites or otherwise) which may be considered Personal Data
Information that we collect or generate about you. This includes (by way of a non-exhaustive list):
Information about the Services which you have purchased and our interactions with you.
When you visit Cold Start Websites, cookies are used to collect technical information about the services that you use, and how you use them. For more information on the cookies used by Cold Start please see our Cookie Notice.
Information we obtain from other sources:
We may be supplied with CV of prospective candidates for roles at both Cold Start and our portfolio companies.
We may from time to time use 3rd party public and private data sources to find out more information about an individual’s employment history.
In addition to the categories of Personal Data described above, Cold Start will also process further anonymized information and data that is not processed by reference to a specific individual.
4. How we use your information
4.1 — Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
For ongoing review and improvement of the information provided on or operation and security of Cold StartWebsites.
To assess your application for our Services, where applicable.
To set you up as a customer.
To provide you with our Services.
To understand feedback on our Services and to help provide more information on the use of those products and services quickly and easily.
To communicate with you in order to provide you with services or information about Cold Start and our products and services.
To understand your needs and interests.
For the management and administration of our business.
In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.
For the administration and maintenance of databases storing Personal Data.
5. Social Media
5.1 We may maintain presence on several social media platforms, such as LinkedIn, Twitter and Facebook, and we may also incorporate some third party social media features onto the Cold Start Websites. We may also include tools on the Cold Start Websites that allow you to share and/or publicly post content or information from the Cold Start Websites 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 Cold Start Websites.
6. Third Party Websites
6.2 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 Cold Start Websites (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.
7.1 We do not intentionally gather personal information from visitors who are under the age of 13. If a child under 13 submits personal information to Cold Start and we learn that the personal information 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 information from a child under 13, please contact us at email@example.com
8. Users Outside the United States
9. Contact Information
2875 NE 191st St, Suite 500, Office 540
Aventura, FL 33180
IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third parties with whom we share Personal Information.
Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
HOW TO EXCERCISE YOUR RIGHTS
You may exercise your California privacy rights described above as follows:
Right to information, access and deletion. You can request to exercise your information, access and deletion rights by emailing us firstname.lastname@example.org
We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights. As part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
PERSONAL INFORMATION THAT WE COLLECT, USE AND SHARE
“Commercial Information” means records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
“Education Information” means Personal Information from an educational record, which could include: a student’s name, the names of the student’s parent or other family members, the address of a student or student’s family, a student’s personal identifier (e.g., SSN, student number), other indirect identifiers of the student (e.g., date of birth, place of birth, mother’s maiden name), other information that, alone or in combination, is linked or linkable to a specific student that would allow a reasonable person in the school community, who does not have personal knowledge of the relevant circumstances, to identify the student with reasonable certainty, or information requested by a person who the educational agency or institution reasonably believes knows the identity of the student to whom the education record relates.
“Financial Information” means bank account number, debit or credit card numbers, insurance policy number, and other financial information.
“Identifiers” means real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
“Online Identifiers” means an online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device.
“Professional or Employment Information” is not defined in the CCPA, but likely includes any information relating to a person’s current, past or prospective employment or professional experience (e.g., job history, performance evaluations).
“Protected Classification Characteristics” includes age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).