1.1

This website privacy policy (the “Website Privacy Policy”) describes the types of personal
information VMG Partners II, LLC and its affiliates (together, “VMG Partners”, “we”, “our”, “us”)
receives about you when you visit www.vmgpartners.com (the “Website”) or collects about you in
other contexts to assist us in supporting our portfolio companies and general ecosystem networking.
It describes what we do with your personal information, how we protect it, and how you can contact
us if you have a question or concern about the personal information we hold about you. Personal
information does not include information that is aggregated or deidentified such that the information
cannot be reasonably linked to you. When data is deidentified, we maintain it in deidentified form and
do not attempt to reidentify the information.

1.2

Your use of this Website is also subject to the Terms of Use available on the Website.

1.3

If you are an investor or potential investor in a VMG Partners fund entity, or affiliated co- investment
entity, or a representative thereof (together, “VMG Investors”), information we collect about you is
governed by a different privacy policy which will made available to you separately.

1.4

VMG Partners may be contacted at the below for all questions relating to this Website Privacy Policy
and your rights under the California Consumer Privacy Act of 2018, as amended by the California
Privacy Rights Act of 2020 (the “CCPA”):

E-mail: compliance@vmgpartners.com
Phone: 833-742-0960 (toll free)
Address: 39 Mesa Street, Suite 310, San Francisco, CA 94129

2.1

When you visit the Website, you may provide us with certain information about yourself. We
collect and use, and have collected and used over the last twelve (12) months, the following categories
of personal information about visitors to the Website:

(a)

Identifiers, including your name and contact information (such as your email address) which
you may choose to submit to VMG Partners using any means of contact listed on the Website,
including the “Contact Us” form; and

(b)

Other information, including any message you submit through the “Contact Us” form, and
information you submit when you make requests pursuant to Section 7.

2.2

In such instances, we will use such information to maintain our business records, manage our
relationship with you, communicate with you, and comply with applicable law, regulation, legal or
judicial process or audit, decision of a court or arbitral tribunal, decision of a governmental authority
with relevant powers, or by the rules of applicable stock exchange or recognized market place, or
requested or required by a regulator, bank examiner or self-regulatory organization or pursuant to
mandatory ethics rules (together, “Law”).

3.1

We may receive certain information about you when you interact with us outside the context of
the Website, including in person, over email and telephone, and from third parties, including our
portfolio companies. We collect and use, and have collected and used over the last twelve (12) months,
the following categories of personal information:

(a)

Identifiers, including your name, contact details (such as your telephone number, email
address, mailing address/location), and date of birth;

(b)

Personal information listed in the California Customer Records statute such as name, telephone number and address;

(c)

Professional or employment-related information, including job title or role;

(d)

Financial information, including compensation information;

(e)

Sensitive personal information, including information on your ethnic and racial origin; and

(f)

Characteristics of Protected Classifications under California or Federal Law, including
diversity information such as gender.

3.2

In such instances, we will use such information to support our portfolio companies, including in
relation to their recruitment management, and our current and/or prospective investors, as well as to
communicate with you comply with applicable Law. We only use sensitive personal information as
permitted by applicable Law, including the CCPA, or otherwise with your consent.

4.1

We disclose, and have disclosed over the last 12 months, personal information collected about you with selected third parties. The categories of recipients include the following (which may be updated from time to time):

(a)

Web hosting service providers, including WP Engine;

(b)

Email and other IT service providers, including Global Relay and Microsoft 365;

(c)

Investor Portal service providers, including Allvue;

(d)

CRM Database service providers, including Crelate and Affinity;

(e)

Various Portfolio Management tools;

(f)

Providers of professional advisory services, including consultants, legal advisors and accountants and other third party service providers;

(g)

Our current and/or prospective portfolio companies, and also with current and/or prospective investors (in relation to information collected about you in the context described in Section 3.1);

(h)

To third parties in connection with an asset sale, merger, bankruptcy, or other business transaction; and

(i)

All recipients to whom we may be required to disclose such personal information when required by a valid subpoena or court order, or as otherwise required by applicable Law.

4.2

We only disclose sensitive personal information in deidentified or aggregate form, and therefore do not disclose, and have not disclosed over the last 12 months, sensitive personal information in a manner that identifies you.

4.3

We do not “sell” or “share” (as those terms are defined in the CCPA), and have not “sold” or “shared” any personal information (including sensitive personal information) collected about you in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of individuals under 16 years of age.

5.1

We retain your personal information for as long as reasonably necessary to fulfil the purposes for
which we collected it, for our business and operational purposes (including audits and reporting) and
to meet our legal and regulatory compliance obligations (including to comply with applicable Law,
resolve disputes, and enforce our terms and policies).

5.2

While we maintain certain policies to protect personal information that we may collect, no method of
transmission over the Internet is completely secure. Therefore, while we strive to protect personal
information that we collect, we cannot guarantee absolute security and confidentiality.

6.1

Like many websites, the Website may use “cookies”, which are small data text files that a website
stores on your computer’s hard drive, if permitted by your web browser.

6.2

Cookies may be used to identify you as a unique user when visiting the Website, to enable us to track
usage so that we can improve the Website, for IT system security purposes and to help us in the
ongoing maintenance of the Website.

6.3

This technology does not provide us with any information about your name, address, phone number or email address, or any other directly identifiable information. We may, however, collect and use (and have done so over the past twelve (12) months) Internet or other electronic network activity information, including IP addresses, browser and device information and information regarding your interaction with the Website, which may be considered personal information.

6.4

Most browsers are initially set up to accept cookies. You can reset your browser to notify you when you have received a cookie, or alternatively, to refuse to accept cookies. However, you may not be able to use certain features on websites if you choose not to accept cookies. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/. In addition, “do not track” signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. Like many websites, the Website does not respond to “do not track” signals in your web browser and we do not use or disclose your information in any way that would legally require us to recognize opt-out preference signals such as Global Privacy Control.

7.1

Where applicable, if you are a California resident you may have the following rights under the CCPA
in relation to “personal information” we have collected about you as defined in the CCPA; these
rights are available to the extent required by the CCPA and subject to verification and any applicable
exceptions:

(a)

Right to Know/Access: You have the right to request that we disclose certain information
to you about our collection and use of certain personal information about you as described
below:

(i)

the specific pieces of personal information collected;

(ii)

the categories of personal information collected;

(iii)

the categories of sources from whom the personal information is collected;

(iv)

the purpose for collecting the personal information; and

(v)

the categories of third parties to whom we have disclosed the personal information.

(b)

Right to Delete: You have the right to request that we delete personal information maintained
about you.

(c)

Right to Correct: You have a right to request that we correct inaccurate personal information
maintained about you.

7.2

To request your exercise of the rights described above, please submit a request to us by either:

(a)

Calling us toll-free at 833-742-0960;

(b)

Visiting www.vmgpartners.com; or

(c)

Emailing us at compliance@vmgpartners.com.

7.3

Freedom from Retaliation: You have the right not to be retaliated against for exercising any of the rights above.

7.4

We will need to verify your identity prior to addressing your request, and may ask for additional
information and documents.

7.5

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer
request related to personal information collected about you. To designate an authorized agent, the
authorized agent must provide sufficient information that allows us to reasonably verify that they have
been authorized by you to act on their behalf.

8.1

Persons with disabilities who need assistance accessing this Website Privacy Policy may contact
us as provided for in Section 1.4, and depending on your individual needs, we will grant reasonable
requests to furnish this policy in an alternative format.

9.1

We do not knowingly collect personal information from children under the age of 13. If you are under
13, please do not give us any personal information. If you have reason to believe that a child under
the age of 13 has provided us with their personal information, please contact us as provided for in
Section 1.4 and we will seek to delete that information in our possession.

10.1

This Website may from time to time contain links to other external websites. This Website
Privacy Policy does not apply to third-party websites. We do not control and are not responsible for
the privacy practices or the content of third-party websites.

11.1

We may update this Website Privacy Policy from time to time and will post any changes and take any
other steps required by applicable law when the changes go into effect.