The Meteor Fund is a fiscally sponsored project of New Venture Fund. As such, below is New Venture Fund’s privacy policy.
Last Updated: May 22, 2018
This Privacy Policy (“Policy”) describes and governs the information collection, use, and
sharing practices of New Venture Fund (“NVF,” “we,” “us,” and “our”), headquartered at
1201 Connecticut Ave. NW, Suite 300, Washington, DC 20036, with respect to both
your use of the NVF website at www.newventurefund.org and any other services that
reference this Policy (collectively, the “Services”). For individuals in the European
Economic Area (“EEA”), NVF is considered to be the “controller” of your personal data.
Before you use or submit any information through or in connection with the Services,
please carefully review this Policy. By using any part of the Services, regardless of how
you access the Services, you consent to the collection, use, and disclosure of your
information as further outlined in this Policy. IF YOU DO NOT AGREE TO THIS
POLICY, PLEASE DO NOT USE THE SERVICES. We will continue to evaluate this
Policy as we update and expand the Services and our offerings, and we may make
changes to the Policy accordingly. Any changes will be posted here and you should
check this page periodically for updates. If we make material changes to this Policy, we
will provide you with notice as required by law. Your continued use of the Services will
signify acceptance of the terms of the updated Policy.
Undefined capitalized terms used herein shall have the definitions as set forth in our
Terms of Use.
1. Information We Collect
We collect information in multiple ways, including when you provide information directly
to us, and when we passively collect information from you, such as from your browser
or device.
a. Information You Provide Directly to Us
We may collect information from you in a variety of ways, such as when you:
• Contact us through our website;
• Become a client; or
• Otherwise communicate with us, such as via email.
We will collect any information that you provide to us, which may include, but is not
limited to: (i) name; (ii) email address; (iii) mailing address; (iv) phone number; (v)
workplace information; and (vi) financial information to facilitate your donations and
investments.
You do not have a statutory or contractual obligation to provide us with your information
through our site; however, certain information may be required in order to enter into a
contract with us.
b. User-Generated Content
You may be able to upload comments, photographs, or other content, and related
information, such as your name or email address (collectively, “User Content”). User
Content may be publicly available, and we cannot limit how others may use such User
Content. By contributing User Consent, you agree that you are at least 18 years old;
own, control, or otherwise have the rights to such User Content; and your User Content
does not infringe or violate the rights of any third parties. You hereby grant us a nonexclusive, royalty-free, worldwide, perpetual, transferable, irrevocable, and fully
sublicensable right to use, reproduce, modify, adapt, publish, sell, assign, translate,
create derivative works from, distribute and display any User Content in whole or in part,
as well as your name and other identifying information, including without limitation any
social media identifier, handle, profile picture, image, likeness, posts, statements or
other information available or provided by you, in any form, media, or technology,
whether now known or hereafter developed in connection with the NVF marketing,
advertising and promotional activities referred to above.
c. Information that Is Passively or Automatically Collected
i. Device/Usage Information
We may automatically collect certain information about the computer or devices
(including mobile devices or tablets) you use to access the Services. As described
further below, we may collect and analyze information such as (a) IP addresses,
location information, unique device identifiers, IMEI and TCP/IP address, and other
information about your computer or device(s), browser types, browser language,
operating system, mobile device carrier information, the state or country from which you
accessed the Services; and (b) information related to the ways in which you interact
with the Services, such as: referring and exit web pages and URLs, platform type, the
number of clicks, domain names, landing pages, pages and content viewed and the
order of those pages, statistical information about the use of the Services, the amount of
time spent on particular pages, the date and time you used the Services, the frequency
of your use of the Services, error logs, and other similar information. As described
further below, we may use third-party analytics providers and technologies, including
cookies and similar tools, to assist in collecting this information.
ii. Cookies and Other Electronic Technologies
We may also collect data about your use of the Services through the use of Internet
server logs, cookies and/or tracking pixels. A web server log is a file where website
activity is stored. A cookie is a small text file that is placed on your computer when you
visit a website, that enables us to: (a) recognize your computer; (b) store your
preferences and settings; (c) understand the web pages of the Services you have
visited; (d), enhance your user experience by delivering content and advertisements
specific to your inferred interests; (e) perform searches and analytics; and (f) assist with
security administrative functions. Some cookies are placed in your browser cache while
those associated with Flash technologies are stored with your Adobe Flash Player files.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny
electronic tags with a unique identifier embedded in websites, online ads and/or email,
and that are designed to provide usage information like ad impressions or clicks,
measure popularity of the Services and associated advertising, and to access user
cookies. We also may include Web beacons in email messages, newsletters and other
electronic communications to determine whether the message has been opened and for
other analytics, personalization and advertising. As we adopt additional technologies,
we may also gather additional information through other methods.
Please note that you can change your settings to notify you when a cookie is being set
or updated, or to block cookies altogether. Please consult the “Help” section of your
browser for more information (e.g., Internet Explorer; Microsoft Edge; Google Chrome;
Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies,
including cookies and local storage objects with the Flash management tools available
at Adobe’s website. Please note that by blocking any or all cookies, you may not have
access to certain features or offerings of the Services.
iii. Information from Social Networking Sites and Other Third Parties
Social networking sites, such as Facebook, have their own policies for handling your
information. For a description of how these sites may use and disclose your information,
including any information you make public, please consult the sites’ privacy policies. We
have no control over how any third-party site uses or discloses the personal information
it collects about you.
We may also collect information about you or others through non-affiliated third parties.
For example, to the extent permitted by law, we may, in our sole discretion, ask for and
collect supplemental information from third parties, such as information about your
organization’s history, information to verify your identity or trustworthiness, or for other
fraud or safety protection purposes. We may combine information that we collect from
you through the Services with information that we obtain from such third parties and
information derived from any other products or services we provide.
2. How We Use Your Information
We may use the information we collect from and about you for the following purposes:
• For the purposes for which you provided it;
• To recognize and authenticate you on the Services;
• To initiate or to provide the features, services and products available through the
Services;
• To send you information about your relationship or transactions with us, account
alerts, or other communications, such as newsletters to which you have
subscribed;
• To contact you with information or surveys that we believe may be of interest to
you both regarding our products and Services and those of third parties;
• To process and respond to your inquiries or to request your feedback;
• For internal research and reporting;
• To improve the content and features of the Services or develop new Services;
• For internal recruiting purposes;
• With your consent, to call or send you SMS messages regarding your
relationship with us or offers or services that may interest you;
• To enforce the legal terms that govern your use of the Services; and
• To administer and troubleshoot the Services.
Please note that we may combine information that we collect from you and about you
(including automatically-collected information) with information we obtain about you
from our affiliates and/or non-affiliated third parties, and use such combined information
in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Services. We
may use de-identified and/or aggregated data for any purpose, including without
limitation for research and marketing purposes, and may also share such data with any
third parties, including advertisers, promotional partners, and/or others.
3. When We Disclose Your Information
We may disclose and/or share your information to or with any non-affiliated third parties
under the following circumstances:
• Consent. We may disclose your information to any third parties based on your
consent to do so.
• Service Providers. We may provide access to or share your information with
select third parties who perform services on our behalf, including without
limitation marketing, market research, customer support, data storage, analysis
and processing, and legal services.
• Protection of NVF and Others. You acknowledge, consent, and agree that NVF
may access, preserve, and disclose your information you submit or make
available for inclusion on the Services, if required to do so by law or in a good
faith belief that such access, preservation, or disclosure is permitted by this
Policy or reasonably necessary or appropriate for any of the following reasons:
(a) to comply with legal process; (b) to enforce this Policy or other contracts with
you, including investigation of potential violations thereof; (c) to respond to claims
that any content violates the rights of third parties; (d) to respond to your
requests for customer service; and/or (e) to protect the rights, property, or
personal safety of NVF, its agents and affiliates, its users, and the public. This
includes exchanging information with other companies and organizations for
fraud protection, and spam/malware prevention, and similar purposes.
• Organizational Transfers. As we continue to develop our organization, we may
acquire, merge or partner with other organizations. In such transactions,
(including in contemplation of such transactions, e.g., due diligence) user
information may be among the transferred assets. If any of NVF’s assets are sold
or transferred to a third party, customer information (including your email
address) would likely be one of the transferred business assets.
• Other Nonprofits. We may share, rent, exchange, or sell our mailing list to other
nonprofit organizations as a way of raising extra money to support NVF, including
so that those other nonprofits may send you promotional emails. Where required
by applicable law, we will obtain your consent prior to doing so. Please see
Section 7 below for more information about how to opt out of this sharing.
4. Legal Basis for Processing Personal Data
The laws in some jurisdictions require companies to tell you about the legal ground they
rely on to use or disclose your personal data. To the extent those laws apply, our legal
grounds for processing your personal data are as follows:
• To Honor Our Contractual Commitments to You. Much of our processing of
personal data is to meet our contractual obligations to our clients, or to take steps
at clients’ request in anticipation of entering into a contract with them.
• Legitimate Interests. In many cases, we handle personal data on the ground that
it furthers our legitimate interests in commercial activities such as the following in
ways that are not overridden by the interests or fundamental rights and freedoms
of the affected individuals:
o Customer service
o Marketing
o Protecting our customers, personnel and property
o Analyzing and improving our business
o Managing legal issues
We may also process personal data for the same legitimate interests of our
clients and business partners.
• Legal Compliance. We need to use and disclose personal data in certain ways to
comply with our legal obligations.
• Consent. Where required by law, and in some other cases, we handle personal
data on the basis of consent. Where we handle your personal data on the basis
of consent, you have the right to withdraw your consent.
5. Online Analytics
We may use third-party web analytics services (such as those of Google Analytics) on
our Services to collect and analyze the information discussed above, and to engage in
auditing, research or reporting. The information (including your IP address) collected by
various analytics technologies described in the “Cookies and Other Tracking
Technologies” section will be disclosed to or collected directly by these service
providers, who use the information to evaluate your use of the Services, including by
noting the third-party website from which you arrive, analyzing usage trends, assisting
with fraud prevention, and providing certain features to you. To prevent Google
Analytics from using your information for analytics, you may install the Google Analytics
Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain analytics tools, such as clear GIFs, to
capture data such as when you open our message or click on any links or banners our
email contains. This data allows us to gauge the effectiveness of our communications
and marketing campaigns.
6. Notice Concerning Do-Not-Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web
browsers. We do not recognize or respond to browser-initiated DNT signals, as the
Internet industry is currently still working toward defining exactly what DNT means, what
it means to comply with DNT, and a common approach to responding to DNT. You can
learn more about Do Not Track here.
7. Your Choices and Rights
All users can review and update certain user information by emailing us at
privacy@newventurefund.org. You can unsubscribe from marketing emails by clicking
the “unsubscribe” link they contain. You can also opt out of our sharing of your mailing
information with other nonprofits by emailing us at privacy@newventurefund.org and
describing your request.
Individuals in the European Economic Area and many other jurisdictions have certain
legal rights to obtain confirmation of whether we hold personal data about them, to
access personal data we hold about them, and to obtain its correction, update,
amendment, or deletion in appropriate circumstances. You may also have rights to
object to our handling of your personal data, restrict our processing of your personal
data, and to withdraw any consent you have provided. To exercise these rights, you
please email us at privacy@newventurefund.org with the nature of your request. While
we strongly encourage you to first raise any questions or concerns about your personal
data with us, you also have a right to contact the relevant supervisory authority.
Many of the rights described here are subject to significant limitations and exceptions
under applicable law (e.g., objections to the processing of personal data, and
withdrawals of consent, typically will not have retroactive effect).
8. Transfer
Our computer systems are currently based in the United States, and your personal data
will be processed in the United States, which may not offer the same level of protection
as the privacy laws of your jurisdiction.
9. Children’s Privacy
The Services are intended for general audiences and not for children under the age of
13. If we become aware that we have collected personal information (as defined by the
Children’s Online Privacy Protection Act) from children under the age of 13, we will take
reasonable steps to delete it as soon as practicable.
10.Security
We have implemented administrative, technical, and physical security measures to
protect against the loss, misuse, and/or alteration of your information. These safeguards
vary based on the sensitivity of the information that we collect and store. However, we
cannot and do not guarantee that these measures will prevent every unauthorized
attempt to access, use, or disclose your information since despite our efforts, no
Internet and/or other electronic transmissions can be completely secure.
11.Data Retention
We will hold your information for as long as necessary to fulfill the purposes set forth in
this Policy or as long as we are legally required or permitted to do so. Information may
persist in copies made for backup and business continuity purposes for additional time.
12.Third-Party Links and Services
The Services may contain links to or “frame” third-party websites, applications, and
other services. Please be aware that we are not responsible for the privacy practices of
such other sites and services. We encourage our users to be aware when they leave
our Services and to read the privacy statements of each and every site they visit that
collects their information.
13.Your California Privacy Rights
California Law permits visitors who are California residents to request certain
information once per year regarding our disclosure of “personal information” (as that
term is defined under applicable California law) to third parties for such third parties’
direct marketing purposes. To make such a request, please send an email to
privacy@newventurefund.org with “Shine the Light” in the subject line or write to us at
NVF Advisors, 1201 Connecticut Ave. NW, Suite 300, Washington, DC 20036.
14.Questions About this Policy
If you have any questions about our Policy, you can contact us by emailing us at
privacy@newventurefund.org.