Privacy Policy

1. Information We Collect

We collect information you provide directly to us, information we obtain from your use of our website, and information from third parties.

1.1 Information You Provide Directly

When you contact us, apply for funding, subscribe to our communications, attend our events, or otherwise interact with us, we may collect:

• Your full name and professional title
• Email address and phone number
• Company name, description, and website
• LinkedIn profile and other professional information
• Pitch decks, financial models, and business plans you submit
• Background information relevant to investment review
• Communications you send us, including through email
• Any other information you choose to provide

1.2 Information Collected Automatically

When you visit nurauca.com, we automatically collect certain technical information about your device and browsing behavior, including:

• IP address and approximate geographic location
• Browser type, version, and language settings
• Operating system and device type
• Pages visited, time spent on pages, and navigation patterns
• Referring URL and exit URL
• Date and time of your visit
• Cookie identifiers and similar tracking data

1.3 Information from Third Parties

We may receive information about you from third parties including:

• Professional networks such as LinkedIn
• Co-investors and industry partners who refer founders to us
• Background check and verification services (for investment due diligence)
• Publicly available sources including company registries, court records, and news sources
• Analytics providers who help us understand website usage

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Investment Activity

• Evaluating funding applications and conducting due diligence on potential investments
• Communicating with founders and management teams of portfolio companies
• Managing existing investments and portfolio company relationships
• Reporting to our limited partners as required by our fund agreements
• Complying with securities laws and investment regulatory requirements

2.2 Website and Service Operations

• Providing, maintaining, and improving our website and online services
• Analyzing website usage patterns to improve user experience
• Diagnosing technical problems and ensuring site security
• Personalizing content based on your interests and usage patterns

2.3 Communications

• Responding to your inquiries, questions, and requests
• Sending investment perspective articles, newsletters, and updates you have opted into
• Notifying you about events, conferences, and programs relevant to our work
• Sending administrative communications required by our relationship

2.4 Legal and Compliance

• Complying with applicable laws, regulations, and legal processes
• Enforcing our terms, agreements, and policies
• Detecting, preventing, and addressing fraud, security incidents, or other harmful activities
• Protecting the rights, property, and safety of Nurauca Capital, our team, and others

3. Legal Bases for Processing (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, we process your personal data under the following legal bases:

• Legitimate Interests: Our legitimate interest in operating our investment business, evaluating funding opportunities, managing our portfolio, and communicating with potential and existing portfolio founders.
• Contract Performance: Where processing is necessary to perform a contract with you (such as an investment agreement or service agreement).
• Legal Obligation: Where we are required to process your data to comply with applicable laws or regulations, including securities regulations.
• Consent: Where you have given explicit consent, such as to receive marketing communications. You may withdraw consent at any time.

4. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

4.1 With Our Team and Fund Entities

We share information among Nurauca Capital employees, partners, and affiliated fund entities as necessary for investment operations.

4.2 With Limited Partners

We may share anonymized or aggregated information about our portfolio with our limited partners. We may share non-anonymized information where required by our fund agreements, subject to confidentiality obligations.

4.3 With Co-Investors and Strategic Partners

When evaluating co-investment opportunities, we may share information about potential investments with co-investors such as Sapphire Ventures, subject to appropriate confidentiality agreements.

4.4 With Service Providers

We share information with third-party vendors who perform services on our behalf, including:

• Cloud hosting and data storage providers
• Email communication and CRM platforms
• Analytics and tracking services
• Legal, accounting, and compliance professionals
• Background verification and due diligence services

All service providers are contractually obligated to use your information only as directed by us and to maintain appropriate security standards.

4.5 Legal Requirements

We may disclose your information when required by law, subpoena, or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, investigate fraud, or respond to a government request.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, subject to the following considerations:

• Information submitted in connection with a funding application is retained for at least seven years, whether or not an investment is made, to comply with our investment recordkeeping obligations.
• Portfolio company information is retained for the life of the investment plus at least ten years to meet regulatory requirements.
• Communications and website analytics data are retained for up to three years.
• We may retain certain information for longer periods when required by law or when necessary to resolve disputes or enforce agreements.

6. Data Security

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Access controls limiting employee access to personal information on a need-to-know basis
• Regular security training for all staff
• Vendor security assessments and contractual data protection requirements
• Incident response procedures for potential data breaches

No method of electronic storage or transmission is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security. If you have reason to believe that your information has been compromised, please contact us immediately.

7. Your Rights and Choices

7.1 Access and Correction

You may request access to the personal information we hold about you, and request correction of any inaccurate information. To make such a request, contact us at hello@nurauca.com.

7.2 Deletion

You may request that we delete personal information we hold about you. We will comply with such requests unless we are legally required to retain the information or have legitimate grounds to continue processing it.

7.3 Marketing Communications

You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions in any marketing email you receive, or by contacting us directly.

7.4 Cookies

You can control the use of cookies through your browser settings and our cookie consent banner. See our Cookie Policy for details.

7.5 California Privacy Rights (CCPA)

California residents have the right to know what personal information is collected about them, the right to delete personal information, the right to opt-out of the sale of personal information (we do not sell personal information), and the right not to be discriminated against for exercising these rights.

7.6 EEA/UK Data Subject Rights (GDPR)

If you are located in the EEA or UK, you have the right to access, rectify, erase, restrict processing of, and port your personal data, and the right to object to processing based on legitimate interests. You also have the right to lodge a complaint with your local data protection authority.

8. International Data Transfers

Nurauca Capital is based in the United States. If you are visiting our website from outside the United States, your information may be transferred to, stored in, and processed in the United States. By using our website or providing us with your information, you consent to this transfer. We comply with applicable international data transfer requirements.

9. Children’s Privacy

Our website is not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will promptly delete it.

10. Links to Third-Party Sites

Our website may contain links to third-party websites. This Privacy Policy applies only to nurauca.com. We are not responsible for the privacy practices of third-party sites, and we encourage you to review the privacy policies of any sites you visit.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the revised policy on our website with an updated effective date. Material changes will be communicated through a prominent notice on our website or direct communication to you where appropriate.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us:

• Email: hello@nurauca.com
• Mail: Nurauca Capital Management, LLC, 101 California Street, Suite 3800, San Francisco, CA 94111
• Phone: +1 (415) 555-0198

We will respond to all legitimate requests within 30 days. For complex requests, we may require up to 90 days, in which case we will notify you of the extension.