Privacy Policy
Last updated: 22 March, 2024
This Privacy Policy describes the privacy practices of WiL, LLC and its affiliates (“WiL”, “we”, “us” and/or “our”) with respect to the personal information we collect online in connection with our website https://www.tmfuturefund.com/ ("Website”), our investor portal, and through any website that we own or control and which links to this Privacy Policy (collectively, the “Service” or “Services”).
1. Personal Information We Collect
We may collect two types of personal information about you: (i) personal information that you voluntarily provide when using the Website, the investor portal or on certain other occasions (such as via forms or in emails); and (ii) information that we and our service providers may automatically log from Website visitors or users of our investor portal. We may also obtain certain personal information from third parties, as further described below.
Information you provide to us may include:
· Contact details, such as your first and last name, business email and mailing addresses, phone number, and professional title.
· Account information, such as the username and password you use to access our investor portal, and tax information.
· Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
· Marketing data such as your preferences for receiving our marketing communications and details about your engagement with them.
· Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Website and the Services (in your capacity as our customer’s authorized user), our communications and other online services, such as:
· Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
· Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.
We use the following tools for automatic data collection:
· Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. For example, we use Google Analytics, a web analytics service provided by Google, Inc., which uses cookies to analyze how visitors use our Services. We use the information to compile reports and to help us improve the Services. For more information on Google’s practices, please visit https://policies.google.com/technologies/partner-sites.
· Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Information we obtain from third parties.
· Social media. We may maintain pages on social media platforms, such as Twitter, LinkedIn, Facebook, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
· Other sources. We may obtain your personal information from other third parties, such as publicly-available sources, data providers, financial institutions, professional advisors, credit reference agencies, and financial crime databases.
2. How We Use Your Information
We use your personal information for the following purposes:
To operate our Services:
· Provide, operate, maintain and secure our Services.
· Provide information about our Services.
· Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.
· Respond to your requests, correspondence, questions, and feedback, including to evaluate and/or pursue investment activities such as investment sourcing, opportunity evaluation, investment, and value-add to WiL and Tokio Marine Future Fund portfolio companies.
Improve, monitor, and personalize the Services, including by understanding your needs and interests, and personalizing your experience with the Services and our communications.
Direct marketing. We may send you direct marketing communications about WiL and Tokio Marine Future Fund’s activities, products and services or those of our affiliates via email and other means. You may opt out of our marketing communications as described in the “Your Choices” section below.
Research and development. We may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, and promote our business.
Compliance and protection, including to:
Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
· Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).
· Audit our internal processes for compliance with legal and contractual requirements and internal policies.
· Enforce the terms and conditions that govern our Website and Services.
· Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
We do not sell your personal information or use your personal information for targeted advertising purposes.
3. How We Disclose Personal Information
We may disclose your personal information to:
Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).
Professional advisors. Professional advisors, such as lawyers, auditors, bankers, finance or accounting advisors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, WiL (including, in connection with a bankruptcy or similar proceedings).
Other third parties if you have requested or authorized the disclosure of such information.
4. Job Applicants
When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or that you may provide during the interview process. This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information. We also collect personal information from other sources where relevant for your application, such as employment research firms, recruiters, identity verification services, and information that you make publicly available on websites or social media platforms (for example, LinkedIn). Throughout the recruitment process, we may supplement your personal information in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes. If you accept an offer from us, your personal information will be incorporated into and used as part of your employee record.
We use applicants’ information to facilitate our recruitment activities and process employment applications, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants’ information to administer the employment relationship.
We may also use and disclose applicants’ information to improve our Website and for the compliance and protection purposes described above. In addition, WiL, LLC may disclose personal information of applicants to its wholly owned subsidiary, TBA Inc. (“TBA”) that provides recruitment services. WiL, LLC requires TBA to protect the confidentiality of the information.
5. How Your Information Is Protected
We take reasonable precautions designed to protect your information from loss, misuse or alteration. You should recognize, however, that there is no such thing as “perfect security” on the Internet, and we cannot guarantee the security of your information. In addition, because Internet communications are unsecure, it is also possible that the information you supply to us or your access of any information via the Services will be intercepted during transmission.
6. Your Choices
Opt out of marketing communications. You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communications we send you.
Limit online tracking. There are a number of ways to limit online tracking, which we have summarized below. Please note that these opt-out tools are not associated with WiL and Tokio Marine Future Fund and we cannot guarantee that these tools work as their providers advertise them:
· Blocking cookies in your browser. 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 device and how to manage and delete them, visit https://www.allaboutcookies.org/.
· Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Personal information requests. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to your personal information:
· Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
· Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily-usable format.
· Correction of personal information that is inaccurate or out of date.
· Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
· Appeal our denial of your personal information request by contacting us as set out in the “Contact” section below.
To exercise the above rights, contact us by email at contact@wilab.com or by post at 636 Waverley St. Suite 100 Palo Alto, CA 94301. We will not discriminate against you for exercising any of these rights. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require the authorized agent to have a written authorization confirming that authority.
In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.
7. Other Sites and Services
Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.
8. Retention
The retention period for the holding of personal information will vary and will be determined by us using various criteria including the purposes for our use of particular personal information, any applicable retention periods prescribed by law and our duty to comply with all other applicable legal or regulatory obligations.
9. Contact
If you have any questions about our Privacy Policy or information practices, please contact us at contact@wilab.com or by post at 636 Waverley St. Suite 100 Palo Alto, CA 94301.
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