CommonFund Privacy Policy

LAST UPDATED: 25 OCTOBER 2023

Entropy Protocol Ltd (“Company”, “us” or “we”) respects your privacy and is committed to protecting it through compliance with this privacy policy.

If you are located in Europe when we collect/process your personal information, please refer to the European Addendum below, to understand your rights and our obligations with respect to your data. Data collected when you are in Europe is not subject to the main portion of this policy.

Except as stated above, this privacy policy applies to information we collect:

• On or through the Services;
• In email, text, and other electronic messages between you and the Services;
• Through mobile and desktop applications, if any, that you download from the Services;
• When you interact with our advertising or applications on third-party websites and services, if such advertising or applications include links to this privacy policy; and
• Through any other means associated with or relating to the Services.

This privacy policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services.

Please read this privacy 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 Services. By accessing or using our Services, you agree to the terms of this privacy policy.

This privacy policy may change from time to time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the privacy policy periodically for updates.

Our Services are not intended for children under sixteen (16) years of age. No one under age sixteen (16) may provide any personal information to us or on or through the Services.

We do not knowingly collect personal information from or about children under the age of 16. If you are under 16, do not use or provide any information on our Services or on or through any of its features, or register on the Services, make any purchases through the Services (if such feature is available), use any of the interactive or public comment features of the Services (if such feature is available), or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 16 years of age, we will delete that information (unless publicly available on the blockchain, in which case such deletion is not technically possible).

If you believe we might have any information from or about a child under the age of 16, please contact us at privacy@common.fund. We will delete the information (unless publicly available on the blockchain, in which case such deletion is not technically possible).

We may collect several types of information from and about users of our Services (some of which is considered “personal information” pursuant to applicable law), including:

• Identifiers, such as name, mailing address, e-mail address, or any other information that the Services collect, which applicable law may consider personally identifiable, personal information, personal data, and other such designations;
• Information required to verify your identity (which we will do through our service provider Onfido), including your Biometric Information (as defined in our Biometric information Privacy Policy);
• When you interact with us through third party services made available by HubSpot (customer relationship management); SparkLoop (referral program); Hopin (event registration); and Greenhouse (applicant management);
• Information about the device you use to access the Services, and its characteristics and functionality (including information about your operating system, hardware, mobile network, browser, browser language, etc.);
• Your IP address, Identifier for Advertisers (IDFA), Android/Google Advertising ID, International Mobile Equipment Identity (IMEI), or another unique identifier;
• Referring and exit web pages and URLs;
• Your browsing history, including the areas within our Services that you visit and your activities there, including remembering you and your preferences;
• Certain other device or activity data, including the time of day you visit our Services; and
• Information about your internet connection and internet provider.

We collect this information:

• Directly from you when you provide it to us or our service providers, such as when filling in forms on the Services (including when you register for an account, subscribing to a service, or requesting something from us, or when you fill out surveys) or when interacting with our referral program providers, customer support or service providers.
• Automatically as you navigate through the Services, including through the use of cookies, web beacons, and other tracking technologies (including information about your network or computing device) – please see our Cookies Policy for more details about such data collection;
• From third parties, for example, our business partners;
• Records and copies of your correspondence (including email addresses), if you contact us through the Services;
• When you engage in transactions on our Services;
• When you run searches on our Services; and
• When you contact our customer service agents, if available.

The Services may also offer social sharing features and other integrated tools (such as the Facebook “Share” button), which let you share actions you take on the Services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about you, your equipment, your technology providers, and your activities, including:

• Details of your visits to our Services, including traffic data, browsing patterns, location data, logs, and other communication data and the resources that you access and use on the Services; and
• Information about your device and about your internet connection and service provider, as set forth above.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically may be statistical data and may also include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. This information enables us to:

• Allow you to use and access the Services, including preventing fraudulent activity and improving security;
• Assess the performance of the Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Services;
• Offer you enhanced functionality when accessing the Services, including identifying you when you sign into our Services, and keeping track of your specified preferences;
• Deliver content relevant to your interests on our Services and third-party sites based on how you interact with our advertisements and/or content;
• Estimate our audience size and usage patterns;
• Speed up your searches; and
• Analyze our services and products and perform market research.

When you visit or leave our Services by clicking a hyperlink or when you view a third-party site that includes our plugins or cookies (or similar technology), we may automatically receive the URL of the site from which you came or the one to which you are directed.

We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we may use to filter out users from certain locations where use of our services may not be permissible, and for fraud prevention and security purposes. If you no longer wish for us, our affiliates, or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions on how to do this. Please note that if you disable such features, your ability to access certain features, services, content, or products may be limited or disabled. If you do this, however, please note that some of our features may not be available to you. This is because some of our services offered on our Services are restricted in certain jurisdictions.

The technologies we use for this automatic data collection are further described in our Cookies Policy.

Onfido

We use a service offered by Onfido to perform “know your customer” activities. This service processes your biometric information for various purposes, including to confirm your identity. Please make sure to review the Onfido facial scan policy and release, the Onfido privacy policyand Onfido terms of service, which are all incorporated into this document by this reference.

Google Analytics

We use Google Analytics, a service provided by Google, Inc. (“Google”) for various purposes, including potentially to analyze traffic on our Services, to grow our business, to improve and develop our services, to monitor and analyze use of our services, to aid our technical administration, to increase the functionality and user-friendliness of our services, and to verify that users have the authorization needed for us to process their request. Google may collect your IP address, and other information (although typically not your name), and utilizes the data collected to track and examine the use of our Services, and to prepare reports for us based on your activities online, among other uses. As part of Google Analytics, Google tracks many variables, including what websites you visited prior to coming to our Services, how long you stay on a particular page, and your geographic location. Please be aware that Google uses the data it collects from our Services for its own purposes, and we do not control or direct such usage. Please visit Google's privacy policy to understand how Google uses the information it collects: https://policies.google.com/privacy?hl=en-US.

Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser's DNT option in your browser's preferences. When a user's browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly.

We do not comply with DNT signals from your browser at this time. However, we have implemented a Global Privacy Control (“GPC”) in an effort to honor your choice not to be tracked online. Please keep in mind that this technology is still in its infancy, and will require changes as time goes by, so your request not to be tracked may not always be honored, depending on how the GPC interacts with our systems and your particular browser.

Some content or applications, including advertisements, on the Services may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

We may use information that we collect about you or that you provide to us, including any personal information:

• To present our Services and their contents to you;
• To provide you with information, products, or services that you request from us;
• To provide, maintain and improve the Services;
• To fulfill any other purpose for which you provide it;
• To provide you with notices about your account and/or the Services;
• To interact with you regarding purchases you've made on other websites we operate;
• To monitor and analyze trends, usage and activities in connection with the Services;
• To carry out our obligations, process transactions, send your related information, and enforce our rights arising from any contracts entered into between you and us, including for confirmations, billing and collection, if needed;
• To respond to your comments, questions and requests and provide customer service;
• To notify you about changes to our Services or any products or services we offer or provide through them;
• To send you technical notices, updates, security alerts and support and administrative messages;
• To allow you to participate in interactive features on our Services, if any;
• To develop and create our products and services;
• For behavioral tracking, profiling and advertising;
• For any other purpose for which the information was collected as needed for our business;
• In any other way we may describe when you provide the information;
• For any other purpose with your consent;
• To contact you about our own and third-parties' goods and services that we think may be of interest to you;
• To enable us to display advertisements to our advertisers' target audiences; and
• To communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information we think will be of interest to you;
• To process your job application, manage recruitment process and improve our recruitment strategy and processes generally.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may also disclose personal information that we collect or you provide with external parties, such as:

• To our subsidiaries and affiliates;
• To contractors, service providers, and other third parties we use to support our business and assist us in providing services and offering our products;
• With other companies, organizations, and individuals outside us, where we have a legitimate legal reason for so-doing;
• 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 Company's assets or stock, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our Services' 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; and
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request;
• To enforce or apply the Terms of Use, including this privacy policy, and any other agreements between us, including for billing and collection purposes; and
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to change your password from time to time. We also highly recommend that you use a password that is dissimilar to and cannot be easily found by unauthorized third parties who may have obtained your login credentials to other sites. Keep in mind that if you use the same password for all websites, if someone obtains your credentials for one site, they may be able to then use those credentials to log into any other site you use.

Unfortunately, the transmission of information via the internet is not completely secure. Although we try to protect your personal information, we cannot guarantee the security of your personal information transmitted through or collected through the use of our Services. 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 Services.

California Civil Code Section § 1798.83, known as the “Shine The Light” law, permits users of our Services who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding year, and the names and addresses of those third parties. You may request this information from us no more than once a year, but such request will be handled by us free of charge to you. To make such a request, please send an email toprivacy@common.fund.

Users are able to apply for prospective positions with us through the Services. If you wish to amend or delete your application, please email us at careers@common.fund with the subject “My Application,” but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a limited period of time.

You may update, correct or delete information from your client account at any time by emailing Company at privacy@common.fund. If you wish to delete or deactivate your account, please email us at privacy@common.fund, or opt-out on our Services, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a limited period of time.

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account, if applicable. We may also post a notice on the Services' home page. The date this privacy policy was last revised is identified at the top of this page. You are responsible for periodically visiting our Services and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

E-mail: privacy@common.fund

YOUR CALIFORNIA PRIVACY RIGHTS

This section of the privacy policy applies solely to California residents.

We adopt this Section of the privacy policy in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Certain terms used in this Section of the privacy policy are defined in, and shall have the meanings ascribed to them in the CCPA.

Note that the term “Personal Information”, as used in this California Specific Section of the privacy policy uses the term as it is defined in the CCPA, and not as defined in the main body of this policy.

We have collected the following categories of Personal Information within the last twelve (12) months:

We do not knowingly collect any Personal Information of persons under the age of 16.

California Consumer Rights Pursuant to the CCPA

California consumers have specific rights regarding how your Personal Information is collected and used.

You have the right to request that we disclose to you or your authorized agent acting on your behalf the following information covering the past twelve (12) months:

• Specific pieces of Personal Information that we have collected;
• Categories of Personal Information collected;
• Categories of sources from which Personal Information is collected;
• Categories of Personal Information sold or disclosed for a business purpose.
• Categories of third parties to whom we sold or disclosed the Personal Information for a business purpose; and
• Our business purpose for collecting (or selling) Personal Information.

You have the right to request deletion of your Personal Information (with exceptions noted by law – more on this below).

You have the right to request that your Personal Information not be sold to third parties.

You have the right not to be discriminated against because you exercised these rights.

As permitted by the CCPA, in the event you request deletion of Personal Information that we have collected about you, we may be unable to comply with such a request if your Personal Information is necessary to:

• Complete the transaction for which the Personal Information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you;
• Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another Consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with a legal obligation; or
• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

We will not discriminate against you for exercising any of your CCPA rights. Specifically, we will not do any of the following unless permitted by the CCPA:

• Deny you goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Provide you a different level or quality of goods or services; or
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

We sell Personal Information, as the term “sale” is defined pursuant to the CCPA, but not in exchange for monetary compensation.

In the twelve (12) months prior to the posting of this Policy, we have sold to third parties the categories of Personal Information about California residents set forth below:

In the twelve (12) months prior to the posting of this Policy, we have disclosed for a business purpose the categories of Personal Information about California residents set forth below:

You can exercise all of your rights granted to you pursuant to the CCPA by contacting us at privacy@common.fund.

California law requires us to verify your identity before processing your request. In order to make a request pursuant to the CCPA, you must provide us with your email address, first and last name. If you are requesting specific pieces of Personal Information that we have collected about you, you will also be required to email us at privacy@common.fund a signed declaration under penalty of perjury that you are a California resident and that you are the consumer whose Personal Information is the subject of the request. Note that we will not process your request to disclose specific pieces of information we have about you until we receive this signed declaration, and your request will not be considered timely submitted until we have this document in our possession.

We will review the information you have provided against the information in our databases, and attempt to verify your identity. However, please note that under certain circumstances, we may require you to provide additional information in order to allow us to confirm your identity and your residency before we can process your requests. Also note that you are only entitled to make a Personal Information request up to twice in a 12-month period.

If (or when) you submit your CCPA request by email, please include “California Privacy Rights” as the subject line. If you make a request to exercise your rights under the CCPA by telephone, we may ask you to provide the request in writing so that we may verify your identity.

We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time or information to verify your identity (and if so, why).

A California resident may use an authorized agent to submit a right to know request, a request to delete, or a request to opt-out of the sale of Personal Information here. To use an authorized agent for these purposes, both the resident and the agent will be required to verify their identities with us. For this purpose, the agent will be required to submit a request with their first and last name and email address, and the following information about the consumer on whose behalf they are making the request: first and last name and email address. In addition, the agent will be required to provide via email written authorization from the consumer to act on their behalf in making these requests. If we cannot authenticate the identity of the agent making the request, we may also require that the consumer confirm directly with us that they have in fact authorized their agent to act on their behalf. We may deny a request from an agent who cannot meet these requirements. If the agent has provided a power of attorney pursuant to Cal. Prob. Code Sections 4121 to 4130, then the verification that the consumer has authorized the agent to act on their behalf will not be necessary.

The General Data Protection Regulation (“GDPR”) imposes certain rules in respect of data protection of individuals, and these rules apply to organizations who process personal data related to the offering of goods and services to individuals in the EU, Switzerland and the United Kingdom and its territories (“UK”). We will refer to all of these laws as “GDPR” in this policy.

Entropy Protocol Ltd (the “Company”) is committed to complying with the GDPR with respect to personal data collected from you when you are located in Europe, and this privacy policy contains important information on who we are, how and why we collect, store, use and share your personal information, the rights you have in relation to your personal information and how to contact us and supervisory authorities in the event that you have a complaint.

This section of the privacy policy applies solely to persons located in Europe at the time of personal data collection by us or on our behalf.

The Company respects your privacy and is committed to protecting your personal data. This privacy notice will inform you about how we look after your personal data when you visit our Services and tell you about your privacy rights.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how the Company collects and processes your personal data, whether through your use of our Services or otherwise.

We do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Entropy Protocol Ltd is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

• Full name of legal entity: Entropy Protocol Ltd
• BVI #: 2071186
• Name or title of data privacy manager: Diana Munoz
• Role: Director
• Email address: team@gdeplaw.com
• Postal address: Ellen Skelton Building, Fishers Lane, Road Town, Tortola, British Virgin Islands
• Telephone number: (305) 697-2655

HOW TO COMPLAIN

We hope that we can resolve any query or concern you raise about our use of your information.

The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the EEA member state where you work, normally live or where any alleged infringement of data protection laws occurred or the UK or Switzerland (as applicable to you).

YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on September 10, 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy notice of every other website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the individual's identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data includes first name, last name, username or similar identifier.
• Contact Data includes email address.
• Financial Data includes bank account, wallet IDs and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.
• Profile Data includes your username and password, purchases or orders made by you, your CV, social handles, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our Services and interact with our service providers.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data (i.e., collections or sets of data that do not identify any particular individual) such as statistical or demographic data (collectively, “Aggregated Data”) for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Except for biometric data, discussed below, We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic data). Nor do we collect any information about criminal convictions and offenses.

With respect to biometric data, we use a service called Onfido. Please make sure to review the Onfido Onfido facial scan policy and release, the Onfido privacy policyand Onfido terms of service, which are all incorporated into this document by this reference.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity Data, Profile, Contact Data and Financial Data by filling in forms or by corresponding with us by email or social channels. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our Services;
  • subscribe to our service or publications;
  • request marketing to be sent to you; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Contact Data, Financial Data and Transaction Data from our service providers.
  • Identity Data and Contact Data from publicly available sources, our employees and prospective employees and service providers.
  • Technical Data from our service providers and analytics and cookies providers.
  • Usage Data from our service providers and analytics and cookies providers.
  • Marketing and Communications Data from our service providers, analytics providers and cookies providers.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• In the case of biometric data, with your consent, to confirm your identity.

You have the right to withdraw consent to marketing or biometric data usage at any time by opting outhere.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, and if you have not opted out of receiving that marketing.

You may opt out of receiving promotional emails from us by following the instructions in those emails under “Manage Preferences”, by visiting our Opt Out page here, or by emailing us at privacy@common.fund. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes (except for service providers we use to engage in our own marketing activities).

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by clicking preferences in any email footer and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• External Third Parties as set out in the Glossary below.
• Specific third parties such as the service providers noted in the Glossary below.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal data will be transferred outside the European Economic Area (EEA), UK or Switzerland. Whenever we engage in such transfers, we follow one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or other applicable regulatory body, or which pose what we deem to be a minimal risk of harm.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, UK or Switzerland (as applicable).

We have also put in place security measures intended to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

We store the information described in this Privacy Policy only for as long as necessary to fulfill the purposes identified above. For example, we maintain website log data for a brief period of time, but retain communications we may have with individuals for longer periods to ensure proper and continuous service of those individuals on an ongoing basis. Additional information on our retention policy can be requested by Contacting us.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

• Service providers acting as processors based in the United States and EU who provide [IT and system administration services.
• Professional advisers acting as processors or joint controllers including lawyers, accountants, auditors and insurers based in the United States, who provide consultancy, legal, insurance and accounting services].
• Regulators and other authorities acting as processors or joint controllers based throughout Europe who require reporting of processing activities in certain circumstances.

Service providers

• Hubspot (CRM) - USA
• Sparkloop (Referrals) - USA
• Onfido (Identity Verification) - EU
• Google Analytics (Marketing data) - USA
• Ads Pixel Tracking (Facebook, Twitter, LinkedIn) - USA
• Auth0 (user authentication) - USA
• DataDog (logging) - USA
• Sentry (error logging) - USA
• DocuSign (contracts for recruiting/offers) - USA
• Hopin (event registration) - EU
• Panadol (NDA & MOU Contracts) - USA

Professional advisors:

• Drata (Security Auditors) - USA
• Sensiba San Filippo LLP (Security Auditors) - USA

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.