Privacy Policy

Introduction:
Clocktower Technology Ventures LLC is an affiliated entity of Clocktower Group, which serves as the investment manager for the Clocktower Technology Ventures business.

Investor privacy is a primary concern for Clocktower Group. This privacy notice is being provided to explain Clocktower Group practices for collecting and disclosing the personal information of clients to both affiliates of Clocktower Group and nonaffiliated third parties. For purposes of this privacy notice, an affiliate is an entity that (i) controls Clocktower Group, (ii) is controlled by Clocktower Group, or (iii) is under common control with Clocktower Group. Nonaffiliated third parties are parties who are not affiliates of Clocktower Group.

CONFIDENTIALITY OF PERSONAL INFORMATION
Clocktower Group maintains the confidentiality of nonpublic personal information that a client provides to it. Clocktower Group maintains physical, electronic and procedural safeguards to guard a client’s nonpublic personal information. All third parties that handle information must agree to follow the standards for confidentiality that Clocktower Group has established. In addition, all people who work for Clocktower Group are trained to handle a client’s information properly in order to maintain its security, and only employees who need to know nonpublic personal information about a client to provide services to such client have access to such information.

CATEGORIES OF NONPUBLIC PERSONAL INFORMATION THAT THE CLOCKTOWER GROUP COLLECTS
Clocktower Group collects nonpublic personal information about clients from the following sources: (i) information it receive from clients on applications or other forms; and (ii) information about clients’ transactions with Clocktower Group, its affiliates, or others.

DISCLOSURE OF NONPUBLIC PERSONAL INFORMATION TO AFFILIATES
Clocktower Group generally may share all of a client’s nonpublic personal information with Clocktower Group’s affiliates; provided that such affiliates will be obligated to keep such nonpublic personal information confidential to the same extent as Clocktower Group. Clocktower Group shares information with its affiliates in order to serve the clients better. If a client prefers that Clocktower Group not disclose nonpublic personal information about such client to its affiliates, such client may opt out of those general disclosures. That is, such client may direct Clocktower Group not to make such disclosures (other than disclosures permitted or required by applicable law or otherwise permitted by Clocktower Group’s privacy policy). However, notwithstanding any such opt-out, Clocktower Group will be permitted to disclose personal information to its affiliates to the extent necessary or appropriate for such affiliates to perform services for the benefit of the client.

DISCLOSURE OF NONPUBLIC PERSONAL INFORMATION TO NON-AFFILIATES
Clocktower Group does not sell or market a client’s personal information to nonaffiliated third parties. Clocktower Group’s intent is to respect the clients’ expectations that their personal information will be kept confidential. However, in order to serve the clients better, Clocktower Group will disclose personal information to nonaffiliated third parties (including service providers to Clocktower Group), but only to the extent necessary or appropriate for such third parties to perform services for the benefit of the client and only if Clocktower Group believes that such personal information will be kept confidential by such third parties after such disclosure.

ADDITIONAL INFORMATION ABOUT CATEGORIES OF NONPUBLIC PERSONAL INFORMATION THAT THE CLOCKTROWER GROUP DISCLOSES
Except as required by applicable law and described in this privacy notice, Clocktower Group will not share any other nonpublic personal information about a client with its affiliates or nonaffiliated third parties.

NONPUBLIC PERSONAL INFORMATION OF FORMER INVESTORS
This privacy notice and Clocktower Group’s policy regarding treatment of nonpublic personal information of clients also apply to former clients.

CHANGES TO PRIVACY POLICY
Clocktower Group may modify its privacy policy at any time.