Privacy Policy

Introduction

Insights WM Capital ("we," "our," or "us") is committed to protecting the privacy of individuals who interact with our website located at insightswm.org (the "Website"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Website, including any other media form, media channel, mobile website, or mobile application related or connected to the Website.

Please read this Privacy Policy carefully. If you disagree with its terms, please discontinue use of the Website. We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Website, and you waive the right to receive specific notice of each such change or modification.

We are based in San Francisco, California, and operate as a venture capital fund manager. The Website is an informational resource about our investment activities, team, portfolio, and perspectives on the mobile and consumer internet industries. We do not offer investment products or advisory services through the Website.

Information We Collect

We may collect information about you in a variety of ways. The information we may collect via the Website includes:

Personal Data You Provide Voluntarily

When you use the contact form on our Website, subscribe to our newsletter, or otherwise communicate with us, you may provide us with personally identifiable information such as your name, email address, phone number, company name, job title, and the content of your message. We collect this information only when you voluntarily provide it to us.

If you apply to work with us or submit a pitch for investment consideration, you may provide additional information including professional background, portfolio company details, financial information, and other materials relevant to the purpose of your submission.

Automatically Collected Information

When you access the Website, certain information is automatically collected by our servers and third-party analytics providers. This may include your IP address, browser type and version, operating system, referring URLs, pages viewed, time spent on pages, links clicked, device identifiers, and geographic location information derived from your IP address.

We use this automatically collected information to understand how visitors use our Website, to identify technical issues, to improve the Website's content and functionality, and to measure the effectiveness of our communications. This information is generally collected in aggregated, non-personally identifiable form, though in some cases it may be associated with your IP address or other identifiers.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to track activity on our Website and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. For detailed information about the cookies we use and your choices regarding cookies, please see our Cookie Policy.

How We Use Your Information

We use the information we collect about you for a variety of legitimate business purposes, including:

To respond to your inquiries. When you contact us through our Website's contact form or email us directly, we use the information you provide to respond to your inquiry, follow up on our conversation, and maintain a record of our communications.

To evaluate investment opportunities. If you submit a pitch or inquiry related to potential investment, we use the information you provide to evaluate the opportunity and communicate with you about our interest and the investment process.

To send communications. With your consent, we may send you newsletters, updates about our portfolio companies, thought leadership content, and other communications about our fund and investment activities. You may opt out of these communications at any time by following the unsubscribe instructions in any such communication or by contacting us directly.

To improve our Website. We use automatically collected data about how visitors use our Website to improve its design, content, and functionality. This includes analyzing traffic patterns, identifying popular content, and testing different versions of pages and features.

To comply with legal obligations. We may use and disclose your information as necessary to comply with applicable laws and regulations, respond to legal process, and protect the rights and interests of ourselves, our investors, and third parties.

For legitimate business purposes. We may use your information to prevent fraud, ensure security, conduct due diligence, and manage our business relationships in the ordinary course of our venture capital business.

Disclosure of Your Information

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

Service Providers. We may share your information with third-party service providers who perform services on our behalf, such as email delivery services, website hosting providers, analytics services, and customer relationship management platforms. These service providers are contractually required to use your information only as necessary to provide services to us and are prohibited from using or disclosing your information for any other purpose.

Investment Partners. As part of our investment activities, we may share information about potential investment opportunities with our limited partners, co-investors, and investment advisors, subject to appropriate confidentiality obligations. We will only share personally identifiable information about founders or company representatives in connection with an active investment evaluation process.

Legal Requirements. We may disclose your information if required to do so by law or in response to valid requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your information in the good-faith belief that such disclosure is necessary to comply with a legal obligation, protect and defend our rights or property, prevent or investigate possible wrongdoing, protect the personal safety of users of the Website or the public, or protect against legal liability.

Business Transfers. In the event of a merger, acquisition, reorganization, sale of assets, or similar transaction, your information may be transferred as part of that transaction. We will notify you via a prominent notice on our Website of any change in ownership or uses of your personal information.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include the nature and sensitivity of the information, the purposes for which we collected it, applicable legal requirements, and our legitimate business needs.

Contact form submissions and associated correspondence are typically retained for a period of three to five years. Analytics data is generally retained in aggregated form indefinitely and in non-aggregated form for up to 26 months. Investment-related communications and due diligence materials are retained for the duration of our consideration of a potential investment and for a period thereafter consistent with our record-keeping obligations as a registered investment adviser.

Security of Your Information

We use commercially reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, use, or disclosure. These measures include encrypted data transmission using Transport Layer Security (TLS), access controls that limit who within our organization can access personal information, regular security assessments of our systems and processes, and agreements with service providers that require them to maintain appropriate security measures.

Despite these precautions, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us using the contact information provided below.

Your Privacy Rights

Depending on your location, you may have certain rights with respect to your personal information under applicable privacy laws, including the California Consumer Privacy Act (CCPA), the General Data Protection Regulation (GDPR), and other applicable laws. These rights may include:

Right to Access. You may have the right to request access to the personal information we hold about you, including information about how we use it and who we share it with.

Right to Correction. You may have the right to request that we correct inaccurate or incomplete personal information we hold about you.

Right to Deletion. You may have the right to request that we delete personal information we hold about you, subject to certain exceptions such as our need to comply with legal obligations or pursue legitimate business purposes.

Right to Opt Out. You may have the right to opt out of certain uses of your personal information, including direct marketing communications. You can exercise this right by following the unsubscribe instructions in any marketing communication you receive from us or by contacting us directly.

Right to Data Portability. In some jurisdictions, you may have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another data controller.

To exercise any of these rights, please contact us using the information provided in the "Contact Us" section below. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request.

California Privacy Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information. This section describes those rights and how to exercise them.

California residents have the right to know what personal information we collect, use, disclose, and sell. We do not sell personal information. California residents also have the right to request deletion of their personal information, subject to certain exceptions, and the right to non-discrimination for exercising their CCPA rights.

To make a CCPA request, please contact us as described in the "Contact Us" section below. We will respond to verified requests within 45 days, with one possible extension of an additional 45 days when reasonably necessary.

Children's Privacy

Our Website is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will promptly delete that information. If you believe we may have inadvertently collected personal information from a child under 13, please contact us using the information provided below.

Third-Party Websites

Our Website may contain links to third-party websites, including websites of our portfolio companies, co-investors, and other industry resources. This Privacy Policy applies only to information collected through our Website. We are not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party websites you visit.

International Data Transfers

We are based in the United States, and the information we collect is governed by U.S. law. If you are accessing the Website from outside the United States, please be aware that information collected through the Website may be transferred to, processed, stored, and used in the United States. U.S. privacy laws may differ from those in your country of origin. By using the Website, you consent to the transfer and processing of your information in the United States.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

You can see when this Privacy Policy was last updated by checking the "Last Updated" date displayed at the top of this Privacy Policy. The current version of the Privacy Policy will always be available on the Website.

Contact Us

If you have questions or comments about this Privacy Policy, or if you wish to exercise any of your privacy rights, please contact us at:

Insights WM Capital
Attn: Privacy Officer
San Francisco, California, USA
Email: privacy@insightswm.org

We will respond to your inquiry as promptly as possible and within the timeframes required by applicable law.