Privacy Policy

Last Modified: September 8, 2021

Primary Venture Management, LLC, together with its affiliates and funds (“Primary”, “us”, “our” or “we”), have created this Privacy Policy to explain how we collect, use, store, share, and transfer personal data and information (“Personal Data”) we obtain through our website located at (the “Website”), as well as the Internet services that we offer (together, the “Internet Services”).

This policy applies to information we collect:

  • On this Website.
  • In email messages between you and this Website.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Primary Venture Management, LLC or any third party (including our affiliates and subsidiaries).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. If you are located in the European Union (the “EU”) or the United Kingdom (the “UK”), this Privacy Policy is for informational purposes only. If you are located in the United States of America or otherwise outside the EU or the UK, by using the Internet Services you consent to such use of your Personal Data and agree to the terms of this Privacy Policy. This policy may change from time to time (see Changes). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Personal Data We Collect

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, e-mail address, and IP address;
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

Information You Submit. This may include: (1) your name; (2) contact details, such as your personal or work email address; (3) information about your communications with us, including the Personal Data you provide to us in email or in conversations with our employees and personnel; and (4) your marketing preferences, including any consents you have given us. If you provide Personal Data about any person other than yourself, you must ensure they understand how their Personal Data will be used and that they have given their permission for you to disclose the Personal Data to us and our outsourced service providers to use.

Information We Collect Automatically. We automatically collect certain Personal Data to help us understand how you use the Internet Services (which we will refer to in this Privacy Policy collectively as “Usage Data”). For example, each time you visit the Website we may automatically collect your IP address, browser, and computer or device type, access time, the webpage from which you came and the webpage(s) that you access during your visit. We may combine Usage Data with other Personal Data in a manner that enables us to trace Usage Data to an individual user.

Information We Collect From Third Parties. On occasion, we may receive Personal Data from third party sources, such as where our trusted suppliers provide web analytics and reporting services to us.

Cookies. We may use cookies (which are small amounts of data sent from a web server to your browser that are stored on your computer’s hard drive) to keep track of your use of the Internet Services, to validate your identity, to remember your preferences, to tailor the Internet Services to you and to meet your interests, and to improve the quality of the Internet Services. Generally, you can set your browser not to accept cookies or to notify you if you are sent a cookie, giving you the opportunity to choose whether or not to accept the cookie. Please note that if you do set your browser not to accept cookies, certain Internet Services may not function properly.

Children. We do not knowingly collect Personal Data from minors nor do we target the Website to minors.

Our Use of Personal Data. We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
  • To notify you about changes to our Website or Internet Services.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

Our Personal Data Sharing Practices

We employ other companies and individuals to perform functions on our behalf, such as for analyzing data. These third-party service providers have access to Personal Data needed to perform their functions, but we require that they do not use Personal Data for other purposes. Personal Data is not shared with any unaffiliated third parties for their marketing purposes unless we have obtained your consent to do so in accordance with applicable law.

We may disclose Personal Data:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Privacy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Primary about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • In response to subpoenas, court orders, regulatory requests, or legal process, or to establish, protect, or exercise our legal rights and interests or defend against legal claims.
  • If we believe it is necessary in order to investigate, prevent, or take action regarding inappropriate or illegal activities, fraud or situations involving potential threats to the safety of any person or property.
  • If we believe it is necessary to investigate, prevent or take action regarding inappropriate use of the Internet Services or violations of the Terms.

Correcting Your Personal Data

We have controls in place designed to ensure that the Personal Data we collect and process is relevant, accurate, and appropriate for the purposes it is used. If you believe that any Personal Data about you is inaccurate, please let us know by contacting us at katheryn [at] primary [dot] vc. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Do Not Track Signals

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

SEC Regulations S-P, S-AM and the Gramm-Leach-Bliley Act

Some regulators, such as the Securities and Exchange Commission and the Federal Trade Commission, have adopted rules that require financial institutions, like Primary, to provide privacy policy notices to their clients. If you are a natural person who invests with us, that notice will govern how we use your Personal Data for the purposes specified in that notice.


We have implemented measures to help protect Personal Data from loss, misuse, or unauthorized access or disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.


The Website may contain links to other websites. We are not responsible for the privacy practices of any such other website (whether accessed through an advertisement, service or content link) and urge you to review such practices prior to submitting any information or Personal Data to such websites.


We may update this Privacy Policy from time to time. It is our policy to post any changes we make to our Privacy Notice on this page. The date the Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Notice to check for any changes. If you are located in the United States of America or otherwise outside the EU or the UK, by continuing to use the Internet Services after such updates you expressly agree to the terms of the updated Privacy Policy.

Questions and Contact Information

If you have any questions about this Privacy Policy or our privacy practices, please feel free to contact us by email at katheryn [at] primary [dot] vc.