Privacy Policy

Last Updated August 15, 2023

Lightspeed Management Company, L.L.C. (“LSVP”, “us,” “our,” or “we”), a global venture capital firm, has created this privacy policy (“Privacy Policy”) to explain our privacy practices in relation to personal information that we collect through your use of our website (“Website”), in providing our services (for example, if you are a limited partner, a representative or founder of any of our portfolio companies, or an investment professional), from other third parties and through our interactions with you in-person or otherwise (collectively, the “Service” or “Services”).

 

Personal Information We Collect

Information you provide to us

  • Contact and account details such as your first and last name, job title, organization name (if applicable), address, email and phone number, and if you create an account with us (e.g., Lighthouse), your password.
  • Communications that we exchange with you, including when you contact us with questions, feedback or otherwise.
  • Marketing data such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Job applicant data when you use the Jobs section of the website, such as your employment history, and as otherwise described in the Job Applicants section below.
  • Event and webinar data when you register for and attend any of our events or webinars, such as details of the event, your attendance record and any special requirements.
  • Visitor information when you visit our offices and provide attendance information, such as who you are visiting and the date and time of your visit.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection

We, our service providers and our business partners may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the Services, such as:

  • Device information, such as computer or mobile device 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., WiFi, LTE, 3G/4G/5G), and general location information such as city, state, or geographic area.
  • Online activity information, such as pages or screens viewed, how long individuals spend on a page or screen, the website they visited before browsing to our website, navigation paths between pages or screens, information about activity on a page or screen, access times and duration of access, and whether individuals open our marketing emails or click links within them.

We may collect this information automatically via cookies, pixel tags, local storage technologies, web beacons or similar technologies on our website (collectively referred to as “Cookies”). For more information on our use of Cookies, please see our Cookie Policy.

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

  • Marketing partners such as companies that have entered into joint marketing relationships with us.
  • Social media companies such as LinkedIn, Twitter and Facebook, when you interact with our profiles on those services.
  • Publicly available sources such as data providers and government databases.
  • Referrals or nominators such as your friends or acquaintances who may provide us with information about you as part of any of our business initiatives (including competitions, rankings and other partnerships) or separately as part of our recruitment process.

 

How We Use Personal Information

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

Providing and supporting our Services. It is in our legitimate business interests to use personal information to operate, maintain, and provide you with our Services. If we have entered into a contract with you, we will use your personal information as required for us to perform our contractual obligations under the relevant contract.

Communicating with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, updates, security alerts and support and administrative messages.

Improving, monitoring, personalizing, and protecting our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:

  • understanding your needs and interests, and personalizing your experience with the Services and our communications;
  • troubleshooting, testing and research and to keep the Services secure; and
  • investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business. For example, we use anonymized traffic statistics from Google Analytics to recognize and count the number of visitors to the website and to see how visitors move around the website when they are using it to enable us to improve the way the website works.

Marketing and advertising

  • Direct marketing. We may send you LSVP-related direct marketing communications as permitted by law, including by email. Except where consent is required, we undertake such marketing on the basis of our legitimate business interest. You may opt out of our marketing communications as described in the Opt-out of marketing communications section below. Where we seek your consent, you may withdraw your consent at any time by contacting us using the details in the How to Contact Us section below.
  • Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our Website, our communications, and other online services, and use that information to serve online ads that they think will interest you. Where required by law we undertake these advertising activities on the basis of your consent, otherwise we will do so only if it is in our legitimate business interests to undertake such activities.

Administering our events. Where you register for and attend one of our events, it is in our legitimate business interests to use your personal information to complete and fulfil your registration for the event, including sending you a confirmation message, sending you updates on the event you have registered for and providing you with access to the event. If we require sensitive information such as diversity information or health data as part of any of our events, we rely on your consent to be able to use that personal information.

Administering our business initiatives (including competitions and rankings). Where you voluntarily participate or are otherwise nominated as part of any of our business initiatives, it is in our legitimate business interests to use your personal information for the purposes of allowing you to participate in and administering the relevant business initiatives. These can include competitions, rankings, and similar initiatives. If we require sensitive information such as diversity information or health data as part of any of our business initiatives, we rely on your consent to be able to use that sensitive personal information.

Facilitating visits to our offices. Where you visit any of our offices, it is in our legitimate business interests to use your personal information in facilitating your access to our office premises, ensuring the security of our office premises and for our record keeping purposes.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including to:

  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
  • audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • enforce the terms and conditions that govern the Services;
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
  • comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.

 

How We Disclose Personal Information

We may disclose personal information to the following entities:

Firm entities. Our current and future affiliates, meaning entities that control, are controlled by, or are under common control with LSVP, including entities for which LSVP provides management services. Our affiliates may use personal information we disclose to them in a manner consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery and website analytics services).

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

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.

Advertising partners. Third-party advertising companies, including for the interest-based advertising purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, LSVP (including, in connection with a bankruptcy or similar proceedings).

Business partners. Where we partner with third parties to run events or other business initiatives (including competitions, rankings or similar initiatives) we may disclose your personal information to such partners for the purposes of administering the relevant events and business initiatives.

 

Privacy Rights and Choices

Opt out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us. You may continue to receive services-related and other non-marketing emails.

Online tracking opt-out. You can opt out of online tracking as described in our Cookie Policy.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

  • Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
  • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
  • Correction of personal information that is inaccurate or out of date.
  • Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
  • Opt out of sharing your personal information for interest-based advertising. We share personal data with advertising partners that display targeted advertisements to users around the web. You can limit online tracking as described in our Cookie Policy. We do not sell personal information.
  • Additional rights, such as to object to and request that we restrict our use of personal information, and where applicable, you may withdraw your consent to our processing of your personal information.
  • Right to complain. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred. If you reside in the European Economic Area, click here to find your local supervisory authority, and here if you are in the United Kingdom.

To make a request, please email us or write to us as provided in the How to Contact Us section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the How to Contact Us section below.

 

Other Sites and Services

Our Services 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. This Privacy Policy does not apply to such third-party sites or services.

 

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee that your personal information may not be accessed, disclosed, altered or destroyed by a breach of any of our technical, organizational and physical safeguards. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, email sent to or from the Services may not be secure, and you should therefore take special care in deciding what information you send to us via email. Moreover, where you use passwords, ID numbers, or other special access features on the Services, it is your responsibility to safeguard them.

 
 
Job Applicants

When you visit the “Jobs” portion of the website or otherwise apply for employment with us or our Affiliates, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide and that we rely only on your consent to use. Otherwise, we use job applicant information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and to respond to surveys. We may also use this information to provide improved administration of the Services, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

 

International Data Transfers

You will provide personal information directly to our website in the United States. We may also transfer personal information to persons and entities described in the “How We Share Personal Information” section of this Privacy Policy (such as other firm entities and service providers) in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.
When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the How to Contact Us section below.

 

Retention of Personal Information

We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

 

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Services. You are encouraged to visit the Website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. All communications, transactions and dealings on the Website shall be subject to the latest version of this Privacy Policy in force at the time.

 

How to Contact Us

Lightspeed Management Company, L.L.C. is the entity responsible for the processing of personal information and is the data controller in respect of such processing. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to personal information, please contact us by email at legal@lsvp.com or write to us at 2200 Sand Hill Road, Menlo Park, California, 94025.

Alternatively, if you are based in the UK you can contact Lightspeed UK Advisor LLP, by email at legal@lsvp.com, or in writing to 22 Tower St, WC2H 9NS, London, UK.

If you are based in the EU, you can contact Lightspeed France SAS, by email at legal@lsvp.com, or in writing to Kwerk Hausmann, 29-31 Rue de Courcelles, 75008 Paris, France.

If you are based in India and you have any grievance with respect to our Services or the processing of your information, you may write to the grievance officer, Vinayak Mishra, at vinayak@lsip.com.

Fraction Fraction

Faction Ventures, LLC (“Faction”) and Lightspeed Management Company, L.L.C. (“Lightspeed”) are separate businesses that operate independently of each other. Faction is a registered investment adviser under the United States Investment Advisers Act of 1940, as amended. Faction advises its own fund(s) and does not advise any Lightspeed clients, and Lightspeed does not advise Faction or any of its clients. Lightspeed and Faction are parties to an agreement pursuant to which Lightspeed holds certain interests in Faction and the fund(s) Faction manages.

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