22HEALTH VENTURES
PRIVACY POLICY
Effective date: 26 May 2023
Thank you for visiting 22healthventures.com(the “Site”),which is owned and operated by 22Health Ventures (US) LLC (“we,” or “us”). We respect your privacy and, whether you are visiting the Site as an investor, founder, ecosystem partner or member of the general public, you are entitled to the protection of your personal information. Please read thisPrivacy Policy to learn how we treat your personal information.
By using or accessing our Site in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of our Site is at all times subject to our Terms of Use [https://www.22healthventures.com/terms-of-use],which incorporate this Privacy Policy. Any terms that we use in this Privacy Policy without defining them shall have the definitions given to them in t he Terms of Use.
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1. What this Privacy Policy Covers.
This Privacy Policy covers important information and disclosures relating to how we treat Personal Data (as defined in this Section1 below for all purpose of this Policy, other than Section 15 in which this term is separately defined) that we gather when you access or use our Site, but does not cover the practices of companies we don’t own or control or people we don’t manage, nor to the privacy practices of any entity with whom we have an investment relationship, even if you are able to access such entity’s website or service through a link on the Site. It 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 or Singapore should refer to the relevant subsections below. You may feel free to print a copy of this Privacy Policy. If you have a disability, you may access this Privacy Policy in an alternative format by contacting info@22healthventures.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.
This chart details the categories of Personal Data that we may collect and have collected over the past 12 months:
Category of Personal Data:
- Identifying information that you voluntarily choose to provide
Examples of Personal Data We Collect:
- Identifying information in emails or letters you send us
Categories of Third Parties with Whom We Share this Personal Data:
- Service providers
- Business partners
- 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
o When you provide such information directly to us.
o When you send us an email or otherwise contact us.
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
We may use Personal Data about you for the following categories of purposes:
- Providing, Customizing and Improving the Site
o Providing you with the services or information you request.
o Meeting or fulfilling the reason you provided the information to us.
o Providing support and assistance for the Site.
o Improving the Site, including testing, research, internal analytics and product development.
o Personalizing the Site, website content and communications based on your preferences.
o Doing fraud protection, security and debugging.
o Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the“CCPA”).
- Corresponding with You
o Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about us or the Site.
o 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
o Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
o Protecting the rights, property or safety of you, us or another party.
o Enforcing any agreements with you.
o Responding to claims that any posting or other content violates third-party rights.
o 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 disclose your Personal Data to the categories of service providers and other parties listed in this section. For more information, please refer to the state-specific sections below.
Parties with whom we engage in our business
We may share any Personal Data that we collect with various parties with whom we engage in our business in the following categories:
- Service Providers. These parties help us provide our services or perform business functions on our behalf. They include:
o Hosting, technology and communication providers.
o Security and fraud prevention consultants.
- Business Partners. These parties partner with us in offering various services. They include:
o Businesses that you have a relationship with, including our investment fund affiliates
- Parties You Authorize, Access or Authenticate
o Third parties
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth 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 our services and promote our business, provided that we will not share such data in a manner that could identify you.
4. Data Security.
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.
Although we work to protect the security of your account and other 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.
5. Data Retention.
We retain Personal Data about you for as long as necessary to provide our Site and/or services to you, comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law, rule or regulation. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
6. Personal Data of Minors.
We do not knowingly collect or solicit Personal Data about children under 13 years of age, except with parental consent. If we learn that we have collected personal information from an individual under 13 years of age without parental consent, we will delete such information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at info@22healthventures.com.
7. Privacy Rights of CaliforniaResidents.
If you are a resident of California, you have the rights set forth in this section. If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@22healthventures.com.
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including the:
· Categories of Personal Data that we have collected about you.
· Specific pieces of Personal Data that we have collected about you.
· Categories of sources from which that Personal Data was collected.
· Business or commercial purposes for collecting your Personal Data.
· Categories of third parties with whom we have shared your Personal Data.
· Categories of Personal Data shared with third parties for a business purpose over the past 12 months, if applicable.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you, subject to certain exceptions under the CCPA: for example, we may need to retain your Personal Data to provide you with the Site or services or complete a transaction or other action you have requested or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Exercising Your CCPA Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Data or are an Authorized Agent (as defined below) authorized by that person and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will use Personal Data provided in a Valid Request only to verify your identity and complete your request. You may submit a Valid Request by emailing us at info@22healthventures.com.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
We Do Not Sell Your Personal Data
We will not “sell” your Personal Data, as that term is defined in the CCPA, and have not done so over the last 12 months. We do not sell the Personal Data of minors under 16 years of age.
Personal Data Sharing Opt-Out and Opt-In
Under the CCPA,California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We will not share your Personal Data for cross-contextual behavioral advertising, and have not done so over the last 12 months. To our knowledge, we do not share the Personal Data of minors under 16 years of age for purposes of cross-contextual behavioral advertising.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not deny you access to our Site or provide you a lower scope or quality of services if you exercise your rights under the CCPA. If you have any questions about this section or whether any of the above rights apply to you, please contact us at info@22healthventures.com.
8. Privacy Rights of Other UnitedStates 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 info@22healthventures.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. If you are a Nevada Resident, you may exercise this right by contacting us at info@22healthventures.com with the subject line “Nevada Do Not Sell Request”and providing us with your name. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
9. Privacy Rights of Residents ofSingapore.
The Site is hosted and operated in the United States(“U.S.”) by us and through our 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.If you are a resident of Singapore, you may have additional rights under the Personal Data Protection Act 2012 (“PDPA”) with respect to your Personal Data, as outlined below. By using the Site, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the U.S. and will be hosted on U.S. servers, and you authorize us 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.
For this section, we use the terms “Personal Data”and “processing” / “process” / “processed” as they are defined in the PDPA, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” / “process”/ ”processed” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. We will be the controller of your Personal Data processed in connection with your use of the Site. By providing your Personal Data to us, you consent to us collecting, using, disclosing and processing your personal data in accordance with this Privacy Policy.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@22healthventures.com.
Personal Data Collection,Use and Disclosure
The “Categories of Personal Data We Collect”subsection of this Privacy Policy above details the Personal Data that we collect from you, and “How We Share Your Personal Data” details how we may use or disclose your Personal Data.
Data Subject Rights
You have certain rights with respect to your PersonalData, including those set forth below.
· Access: You may request more information about the Personal Data we hold about you and request a copy of such Personal Data.
· Correction: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you may request that we correct or supplement such data.
· Withdrawal ofConsent: If we are processing your Personal Data based on your consent, you have the right to withdraw your consent at any time.
· Portability: You may ask for a copy of your Personal Data in a machine-readable format. You may also request that we transmit the data to another controller where technically feasible.
For more information about these rights, or to submit a request, please contact us at info@22healthventures.com.
Please note that in some circumstances, we may not be able to comply fully 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, to the extent permitted by law, 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.
10. Changes to This Privacy Policy.
We are 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 the Site, 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.
11. Contact Information.
If you have any questions or comments about this Privacy Policy, the ways in which we collect, solicit, store, use, share, disclose or process your Personal Data, or your choices and rights regarding such collection, solicitation, storage, use, sharing, disclosure or processing, please do not hesitate to contact us at info@22healthventures.com.
