Privacy Policy

At Quiet, we respect your privacy and, whether you are visiting the Website as an investor, founder or member of the general public, you are entitled to the protection of your personal information. Please read this Privacy Policy to learn how we treat your personal information when you use our Website, products or services (the “Services”).

By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent to our collection, use and sharing of your information as described in this Privacy Policy. 

Remember that your use of the Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.  As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the Quiet website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

1. What this Privacy Policy Covers.

This Privacy Policy provides important disclosures and other information relating to how we treat Personal Data that we gather when you access or use the Services, but this Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage, nor does this Privacy Policy cover the practices of any entity with whom we have an investment relationship, even if you are able to access such entity’s website or services through a link on the Site. This Privacy Policy also does not apply to information obtained or disclosed in offline correspondence or in connection with an investment in one of our affiliated investment funds. Please note that you may have additional rights to control the use and disclosure of your Personal Data. Residents of California should refer to the relevant subsections below. You may print a copy of this Privacy Policy by clicking here. If you have a disability, you may access this Privacy Policy in an alternative format by contacting compliance@quiet.com.

Use of the term “Personal Data” herein means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.

2. Categories of Personal Data We Collect.

The chart below identifies the categories of Personal Data that we have collected over the past 12 months or may collect in the future:

Category of Personal Data	Examples of Personal Data We May Collect	Categories of Third Parties With Whom We May Share this Personal Data:
Profile or Contact Data	·  First and last name·  Email address	·  Service Providers·  Parties You Authorize, Access or Authenticate
Device/IP Data	·  IP address·  Device ID·  Domain server	·  Service Providers·  Parties You Authorize, Access or Authenticate
Web Analytics	·  Interactions with the Services·  Referring webpage/source through which you accessed the Services·  Non-identifiable request IDs·  Data related to the interaction between device or browser and the Services	·  Service Providers·  Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide	·  Identifying information in your emails, letters, submissions or other communications directed to us	·  Service Providers·  Parties You Authorize, Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

• You
  • When you provide such information directly to us.
    • When you use the Services.
    • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    • When you send us an email or otherwise communicate with us.  
  • When you use the Site and such information is collected automatically.
    • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).

• Third Parties
  • Vendors
  • We may use analytics providers to analyze how you interact and engage with the Services or third parties may help us provide you with customer support.

Our Commercial or Business Purposes for Collecting Personal Data

• Providing, Customizing and Improving the Services
  • Providing you with the Services you request.
  • Meeting or fulfilling the reason you provided the information to us, including to deliver our newsletters and emails.
  • Communicating with you about the Services, including Services announcements.
  • Providing support and assistance for the Services.
  • Improving and developing the Services, including research, testing and internal analytics.
  • Protecting against, deterring or otherwise addressing fraud, security and debugging.
  • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
• Corresponding with You
  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information related to us.
  • Sending emails and other communications according to your preferences or that display content that we think will interest you.
• Meeting Legal Requirements and Enforcing Legal Terms
  • Fulfilling our legal obligations under applicable laws, rules and regulations, court orders and other applicable legal requirements.
  • Protecting against, deterring or otherwise addressing illegal, fraudulent or otherwise harmful actions and maintaining the safety, security and integrity of the Services.
  • Enforcing any agreements with you.
  • Responding to claims that any content available via the Services violates third-party rights.
  • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

3. How we Share Your Personal Data.

We may disclose your Personal Data to the categories of service providers or other parties identified in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

• Parties You Authorize, Access or Authenticate
  • Third parties you access through the Services.
  • Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in furtherance of the purposes described under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services, provided that we will not share such data in a manner that could identify you.

4. Tracking Tools and Opt Out.

The Services may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable the relevant servers to recognize your web browser and tell us how and when you visit and use the Services, to analyze trends, learn about our user base and operate and improve the Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or other device when you use that device to access certain of the Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because we may use Cookies, the Site does not support “Do Not Track” requests sent from a browser at this time

We may use the following types of Cookies:

• Essential Cookies. Essential Cookies may be required for providing you with features or services that you request. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies may be used to record your choices and settings related to our Services, maintain your preferences over time and recognize you when you return to certain of the Services. These Cookies would help us to personalize our content for you and remember your preferences.
• Performance/Analytical Cookies. Performance/Analytical Cookies may be used to enable us to understand how visitors use the Services, such as by collecting information about the number of visitors to the Site or other Services, what pages visitors view on the Site and how long visitors are viewing or engaging with the Services. Performance/Analytical Cookies could also help us measure the performance of any advertising campaign we may launch, in order to help us improve our campaigns and the content of the Services for those who engage with our advertising. 

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To obtain more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

5.  Security and Retention.

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, and administrative security measures and storage and processing practices based on the type of Personal Data.  We retain Personal Data about you for as long as necessary to provide the Services to you, comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data or storing data over the Internet is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

6.  Personal Data of Minors.

We do not knowingly collect or solicit Personal Data about children under 16 years of age. If we learn that we have collected personal information from an individual under 16 years of age without parental consent, we will delete such information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at compliance@quiet.com.

7. Privacy Rights of Certain United States Residents.

California Resident Rights

California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, under California Civil Code Sections 1798.83-1798.84. If you would like to submit such a request, please contact us at compliance@quiet.com.

8.     European Union Data Subject Rights

EU Residents

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.  

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Quiet will be the controller of your Personal Data processed in connection with the Services.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, as further described below.

• Consent:  We process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. 
• Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties. 

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at compliance@quiet.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.  

• Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. 
• Erasure:  You can request that we erase some or all of your Personal Data from our systems.  
• Withdrawal of Consent:  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services. 
• Portability:  You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection:  You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing:  You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint:  You have the right to lodge a complaint about Quiet’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Quiet and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Quiet in the U.S. and will be hosted on U.S. servers, and you authorize Quiet to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission. 

9.   Changes to This Privacy Policy.

We’re constantly trying to improve our Site and services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on our website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Site and/or services, and you are still responsible for reading and understanding them. If you use the Site and/or services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

10.    Contact Information.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at compliance@quiet.com.