August Capital Master Management Company, LLC (“we,” “us” or “our”) is the management company for the August Capital and Lobby Capital venture capital funds. We are committed to respecting and protecting your privacy. Please read the following carefully to learn more about our Privacy Policy. By using or accessing augustcap.com (the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent that we will collect, use, and share your information as described herein. Your use of the Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy, including definitions of any terms used herein. We reserve the right to change this Privacy Policy at any time. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

If you have any questions or concerns regarding our privacy policies, please contact us at notices@augustcap.com.

Information covered under this Privacy Policy

This Privacy Policy covers our treatment of information (which may include personally identifiable information and any “personal identifiers” as that term is defined in the California Consumer Privacy Act (“CCPA”) (“Personal Information”)) that we gather when you are accessing or using our Services. It does not apply to information obtained or disclosed in offline correspondence, through other personal contacts with our representatives or through the practices of companies we don’t own or control, or people that we don’t manage. For clarity, this policy explicitly does not cover the privacy practices of any entity with whom we (or any of our affiliates) has an investment relationship, even if you are able to access such entity’s website or service through a link on the Services.

We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under the age of 13, please do not attempt to send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible.

Collection of Information

Information You Provide to Us:

We receive and store any information you knowingly provide to us. For example, you may choose to provide information through the online messaging form on our “contact” page, which may allow you to provide us Personal Information such as your name and email address.

Information Collected Automatically

We automatically receive and record information regarding your usage of the Service, which may include your IP address, geolocation data, device identification, “cookie” information, the type of browser and/or device you’re using to access our Services and the page or feature you requested. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from taking advantage of some of our features. If you click on a link to a third-party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices.

Use of Information

Upon our collection of your Personal Information, we may use and disclose such Personal Information internally and to our affiliates and service providers, separately or in combination with pre-existing information, for the following business purposes:
• To provide any requested information or services;
• To troubleshoot problems with the Services;
• To customize your experience on the Services;
• To analyze how you and others use the Services;
• To enforce our Terms of Use and other agreements, or compliance with this Privacy Policy;
• To contact you with more information about us;
• To comply with law, court order or other legal process; or
• To protect our rights, property, or safety (including on behalf of our affiliates, employees, users, or others.

We do not sell or otherwise disclose your information to third parties for monetary or other valuable consideration. Please note that while we endeavor to protect the privacy of your Personal Information we collect; we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
You may request the specific pieces of personal information we have collected from you and/or request that we delete the personal information that we have collected from you by contacting us at notices@augustcap.com. However, we may need to retain such information in certain circumstances if it is necessary to provide you with services you requested or if we use such data only for our internal analytical use. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you access to our Services or provide you a lower quality of services if you exercise your rights under the CCPA.

Transfers of Personal Information

The Services are hosted and operated in the United States (“U.S.”) through us and 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. By using the Services, you acknowledge that any Personal Information 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. pursuant to EU-U.S. Privacy Shield Frameworks, the details of which are further set forth below: (i) a data processing agreement incorporating standard data protection clauses, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.

While the Privacy Shield is no longer a valid basis on which we may rely to transfer Personal Information from the EU to the U.S. pursuant to the GDPR, we continue to comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Information from EU member countries transferred to the U.S. pursuant to Privacy Shield. We have certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Privacy Policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU individuals have the right to obtain our confirmation of whether we maintain Personal Information relating to you in the U.S. Upon request, we will provide you with access to the Personal Information that we hold about you. You may also correct, amend, or delete the Personal Information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the U.S. under Privacy Shield, should direct their query to notices@augustcap.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide you with the choice to opt-out, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than the purpose for which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your Personal Information, please submit a written request to notices@augustcap.com.

In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.