Clocktower Technology Ventures LLC is an affiliated entity of Clocktower Group, L.P., which serves as the investment manager for the Clocktower Technology Ventures business. Clocktower Technology Ventures LLC, Clocktower Group, L.P., and/or any of its affiliates (together and/or separately, as the context may require, “Clocktower” or “we” or “us”) may collect and process certain personal data about you (i.e., information that identifies you).
This privacy notice sets out the basis on which personal data about you will be processed by Clocktower. If you are dealing with Clocktower (i) in a capacity of an officer, employee, director, contractor, agent or principal of (a) a past or prospective client of Clocktower or investor in a fund managed by Clocktower, (b) a counterparty of Clocktower or a fund managed by Clocktower; or (c) a service provider; (ii) as a director of any of Clocktower fund; or (iii) as an individual interested in a career at Clocktower, please take the time to read and understand this privacy notice.
Personal Data that We Collect About You
Clocktower may collect and process some or all of the following personal data about you which you provide to us by filling in forms or by communicating with us, whether face-to-face, by phone, in writing or by e-mail or which we otherwise collect in the course of our interactions.
Information that you may provide to us:
Information we collect or generate about you:
Some of the above information (such as biometric data, civil and criminal conduct history, health information, political affiliations) is categorized as sensitive personal data. As with any personal data, we will only collect and process sensitive information where we have a legal basis for such collection and processing, including where required or permitted under applicable law or where we have your consent (where we are legally required to do so).
You are not required to supply any of the personal data that we request. However, failure to supply any of the personal data that we request may result in our being unable to provide services to you or your company, discuss any business opportunities with you or deal with other matters.
Uses of Your Personal Data
Your personal data may be stored and processed by us for the following purposes:
Clocktower is entitled to process your personal data in these ways for the following reasons:
Disclosure of Your Information to Third Parties
We may share your personal data within the Clocktower group for the purposes of: (i) management and administration of our business, (ii) complying with the functions that each of the entities may perform, (iii) regional or global investor relations or HR activities (iv) assessing compliance with applicable laws, rules and regulations, internal policies and procedures across our business and (v) enabling adequate communication with you.
Clocktower may from time to time, in connection with the purposes described in the previous section, disclose your personal data to third parties outside of the Clocktower group, including (i) third parties that process your personal data on our behalf; (ii) professional advisers such as law firms, auditors, and accountancy firms, (ii) recruitment consultants, travel agents, payments, technology and communication service providers, (iii) counterparties and (iv) courts and regulatory, tax and governmental authorities.
Clocktower will make reasonable efforts to ensure that your personal data is accessed by the Clocktower group’s staff and third parties on a need-to-know basis and subject to general confidentiality arrangements.
Protecting Your Personal Data
We are committed to safeguarding and protecting your personal data and we maintain appropriate security measures to protect your personal data from improper, unauthorized, unlawful or accidental disclosure, destruction, alteration, use, access, loss or damage.
Retention of Personal Data
How long Clocktower holds personal data for will vary. The retention period will be determined by various criteria, including the purposes for which Clocktower is using it and legal obligations (as laws or regulations may set a minimum period for which Clocktower has to keep your personal data).
U.S. natural persons:
To the extent you are a U.S. natural person, U.S. federal law gives you the right to limit: (i) Clocktower’s sharing of your personal data with our affiliates for their everyday business purposes if such information concerns your creditworthiness, (ii) Clocktower from using your personal data to market to you, and (iii) Clocktower sharing of your personal data with non-affiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. To protect your personal data, we permit access only by authorized employees who need access to that information in order to perform their jobs. To protect your personal data from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
E.U. natural persons:
Your personal data may be transferred to and stored by persons outside of the European Economic Area (the “EEA”), and in particular may be transferred to and stored by individuals operating outside of the EEA who work for a non-EEA Clocktower group entity or a third party.
Where personal data is transferred outside of the EEA, Clocktower will ensure that the transfer is subject to appropriate safeguards or is otherwise permitted under applicable law. For example, the country to which the personal data is transferred may be approved by the European Commission, the recipient may have agreed to model contractual clauses approved by the European Commission that oblige them to protect the personal data, or the recipient may be located in the United States and be a certified member of the EU-US Privacy Shield scheme.
Pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation), you have a number of legal rights in relation to the personal data that we hold about you. These rights include:
You can find out more information about your rights at the European Commission’s website, https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en, or by contacting the UK’s Information Commissioner’s Office or searching their website at
Updates to this Privacy Notice
We may change or update portions of this privacy notice to reflect changes in our practices and or applicable law and regulation. Please check this privacy notice from time to time so you are aware of any changes or updates. Where required under applicable data protection and privacy laws, we will notify you of any change or update portions of this privacy notice by individual message or by disclosing the changes to the data processing on a publicly available medium.
If you would like further information on the collection, use, disclosure, transfer (including the protection given to your personal data when it is transferred outside of the EEA), or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to your usual contact at Clocktower or business administration on +1 310-458-2003 and firstname.lastname@example.org.