Privacy Policy

Effective as of November 5, 2023.

This Privacy Policy describes how GGV Capital U.S. and our affiliates and subsidiaries (“GGV,” “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, social media pages, marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”). GGV may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.

California residents: See our Notice To California Residents for information about your personal information and privacy rights.

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email address, mailing addresses, professional title and company name, phone number and other contact details.
• Account data, such as the username and password that you may set to establish an online account on the Service, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.
• Company data, such as any information about you, your colleagues or your company that you share with us in relation to investments or potential investments in your company by the funds we manage, such as your and colleagues’ professional and educational backgrounds.
• Communications data, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us.
• Marketing data, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
• Event registration data, such as information you provide and/or we collect when you register for or attend in-person or online events that we host or co-host (e.g., photographs).
• Survey data, such as the information you provide to as part of Security4Startups assessments.
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Business contacts who send us information about entrepreneurs or candidates for jobs with our portfolio companies.
• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer 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, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, 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 Service, 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 emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails), which we collect through pixel tags (also known as clear GIFs) in our emails.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• 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, helping us understand user activity and patterns, and facilitating analytics and online advertising.
• Local storage technologies, like HTML5 and Flash, 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.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Referrals. Users of the Service may have the opportunity to nominate or refer other contacts to us. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

We may use your personal information for the following purposes or as otherwise described at the time of collection:

To operate the Service. We use your personal information to:

• provide, operate and improve the Service.
• provide information about our products and services.
• establish and maintain your user profile on the Service.
• explore business opportunities and execute transactions, including our investments in companies and investments in the funds we manage.
• communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages.
• communicate with you about events or surveys in which you participate.
• understand your needs and interests, and personalize your experience with the Service and our communications.
• help our portfolio companies explore business opportunities and recruit and evaluate job candidates.
• provide support and maintenance for the Service.
• respond to your requests, questions and feedback.

For research and development. We analyze use of the Service to analyze and improve the Service and to develop new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications. We may send you GGV-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt-out of marketing section below.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service.
• Functionality. To enhance the performance and functionality of our services.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection. 

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Service (such as hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Portfolio companies. We may share personal information about job candidates and other business contacts with portfolio companies with whom we are collaborating to assist those companies with their business and recruiting activities.

Investors. We may share with investors and prospective investors in our funds the biographies and other information about the founders and key personnel of our portfolio companies.

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. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. 

In this section, we describe the rights and choices available to all users. Users who are residents of California can find additional information about their rights below.

Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@ggvc.com. You may continue to receive service-related and other non-marketing emails.  

Cookies. 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. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit https://allaboutcookies.org/. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

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 https://allaboutdnt.com/.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.

The Service 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. We encourage you to read the privacy policies of the other websites and online services you use.

• Email: privacy@ggvc.com
• Mail: 3000 Sand Hill Road, Building 4, Suite 230, Menlo Park, CA 94025
• Phone: (650) 475-2150

This notice describes our collection, use and disclosure of personal information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to their personal information. For purposes of this notice, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.

Your privacy rights. As a California resident, you have the following rights under the CCPA:

• Right to know.You can request information about 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, sharing and/or selling personal information; the categories of any personal information that we sold or disclosed for a business purpose; and the categories of any third parties with whom personal information was sold, shared or disclosed for a business purpose.
• Right to access. You can request a copy of certain personal information that we have collected about you.
• Right to deletion. You can request that we delete personal information that we collected from you.
• Right to correction. You can request that we correct inaccurate personal information that we have collected about you.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Identity verification. You may submit requests to exercise your right to know, access, deletion and correction to https://www.ggvc.com/ccpa-request-form or via email to privacy@ggvc.com. The rights described above are not absolute, and in certain cases, we may decline your request as permitted by law. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. 

Authorized agents. We need to verify your identity to process your requests to exercise your rights to know, access, deletion, and correction, and we reserve the right to confirm your California residency. To verify your identity, we may require you to log into an online account if you have one, provide identifiers we can match against information we may have collected from you previously, confirm your request using the email or telephone account stated in the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law. If you have not provided your agent with such a power of attorney, we may ask you and/or your agent to take additional steps permitted by law to verify that your request is authorized, such as information required to verify your identity and that you have given the authorized agent permission to submit the request.

Information practices. The following describes our practices currently and during the past 12 months:

• Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in the Privacy Policy.
• Sales and sharing of personal information. We do not “sell” or “share” personal information as those terms are defined in the CCPA and have no actual knowledge that we have sold or shared the personal information of California residents under 16 years of age.
• Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.
• Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
• Deidentification. We do not to attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
• Collection and disclosure. The chart below describes the personal information we collect by reference to the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140), and the categories of third parties to whom we disclose it. The terms in the chart refer to the categories of information and third parties described above in this Privacy Policy in more detail. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. We may also disclose personal information to professional advisors, law enforcement and government authorities, and business transferees as described above in the How We Share Your Personal Information section of this Privacy Policy.