Introduction 

GGV Capital (“GGV,” “we,” “us,” or “our”) recognizes the importance of your privacy and the need to protect information that users of our website, located at https://www.smbtech50.com/ (the “Website”), provide to us, including in connection with the nomination process for our SMBTech 50 List (the “List Process”), or that we obtain through other ways of interacting with you, including interactions ancillary to the List Process (collectively, the “Services”). This Privacy Policy (the “Privacy Policy”) explains our data collection practices, how we may use and disclose that information, the steps we take to keep it secure, your choices regarding our use of this information, and how you how can contact us if you have any questions about our privacy practices. We will refer to the personal information and other information we obtain about you that we consider “private” or “personal information” as “Your Data.” Please read our complete Privacy Policy. By visiting our Website or using our Services, you accept the practices described in this Privacy Policy. We will occasionally update this Privacy Policy. When we do, we will also revise the “last update” date at the top of this Privacy Policy. Capitalized terms used herein and not otherwise defined have the meaning set forth in our Terms and Conditions.

1. Information We Collect

a. Information you provide to us 

We collect information from and about you directly when you provide it to us. This information may be collected when you fill out a Nomination form, access or participate on our Website, respond to surveys or inquiries about your business in connection with the List Process, or otherwise interact with us, such as through social media or networking sites. This information may include: 

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• “Contact Information,” such as your name and e-mail address; Contact Information is collected when you respond to our “contact us” link and in connection with our Nomination form;
• Information about your business or the business you nominate in connection with the List Process, including certain financial information; and 
• Any other information you voluntarily provide.

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b. Information we collect automatically

Like most online services, we automatically receive standard technical information when you connect with the Services. We collect this information through browser cookies, pixel tags, web server logs, web beacons, embedded scripts, and similar technologies. These features enable us to personalize your experience with the Services, understand how you use them, maintain a persistent session, and improve and further develop the Services. We collect this information as follows:

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• Web server cookies: A cookie is a small piece of information that is sent by our web server, stored on your PC’s hard drive, and used by your web browser to “remember” information about your visit. We use cookies to help us collect information and to enhance your experience using the Services. Specifically, we use cookies to authenticate users, personalize your experience when using the Services, analyze which features of the Services you use most frequently, and measure and optimize advertising and promotional effectiveness. To do this, we may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them. If you do not want the Services to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, some aspects of the Services may not function properly.
• Pixel Tags: Certain Services and websites may contain electronic images known as pixel tags (also called web beacons or gifs) that we use to help deliver and recognize cookies on our websites, count users who have visited those websites, and gather usage and performance data. We also include pixels in our emails to tell if you open and act on them.
• Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
• Log files: Like most standard website servers, we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses etc. are tied to personally identifiable information to enable our web-based service.
• Device information: We collect information about the device you use to access or use the Website, including the hardware model, operating system and version, unique device identifiers, network information and information about your use of our applications.
• Geolocation information: We may automatically collect geolocation information from your device, your wireless carrier, or certain third-party service providers (“Geolocation Information”). You may control the collection of Geolocation Information through the user settings on your device. You may decline to allow us to collect such Geolocation Information, in which case we may not be able to provide certain services to you. 

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c. Information we collect through third-party data and analytics providers

We use third-party data and analytics services (including as Google Analytics) to evaluate your use of the Services, compile reports on activity, collect demographic data, enhance our data with other information about our users, analyze performance metrics, and collect and evaluate other information relating to the Services and mobile and internet usage. These third parties use cookies and other technologies to help analyze and provide us the data and may also collect information regarding your use of other websites, apps, and online resources, and across your electronic devices.

For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.

d. Tracking Data

We may collect tracking data using first and third-party cookies, pixels, web server logs, web beacons, and similar data collection and tracking technologies on the Website, third party websites, apps and online services, and across your devices (such as IP address, browser, type, ISP, platform type, device type). Third parties such as advertising networks and analytics providers may also collect information about your online activities over time and across different websites and devices when you access or use the Services.

2. How We Use Your Data

We use Your Data to provide the Services to you, and to operate our business. This includes:

• Service-related usage: We use Your Data to provide and support the Services, including operating the Website, and receiving Nominations. 
• Communication: We use Your Data to communicate with you and respond to your requests and questions; to contact you about your Nomination and to contact Nominees in connection with the evaluation and selection process relating to the SMBTech 50 List; or changes to the Website.
• SMBTech 50 List: To announce and publicize companies that are selected for the SMBTech 50 List.
• Marketing and Advertising: If you enter your contact information on the Website and opt-in to receive electronic marketing communications from us, we may contact you for marketing purposes, such as to communicate with you about our business and services, and possible collaborations. We will not send you marketing emails if you have not signed up for this, and you can unsubscribe from receiving such emails at any time by clicking on the “unsubscribe” link at the bottom of all our marketing emails.
• Analyzing and improving the Services: We may run calculations, aggregate, normalize, clean, enhance and make derivative works of the information obtained about you in order to:

• Advertising: GGV, its business partners and advertising/marketing companies may use Your Data to tailor, analyze, manage, report and optimize advertising you see on or through the Services, and on other sites and apps that you access and/or use through your devices. By accessing and using the Services, you consent to the processing of Your Data for these purposes.

3. How We Share Your Data

We may share, transfer, or disclose Your Data if you ask us to do so, as well as in the following circumstances. We will take reasonable measures to require that any party receiving any of Your Data from us undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of Your Data.

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a. To assist us running our business and providing our Services to you

We may employ other companies and individuals to perform functions on our behalf, such as website hosting, data analysis and enhancement, information technology and related infrastructure provision, communication and data collection support, and email delivery. GGV will also share Your Data with third parties that help us in selecting and publicizing The SMBTech 50 List, provided that such parties shall not receive your full financial information. These other companies will have access to Your Data only as necessary to perform their functions and to the extent permitted by law.

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b. To better understand and serve Users

In an ongoing effort to better understand our Users, we might analyze Your Data in aggregate form in order to operate, maintain, manage, and improve the Services. This aggregate information does not identify you personally or associate your financial information with you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

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c. For advertising and marketing purposes

We may share information about your activity in connection with your use of the Services, including tracking data, with third-party advertisers and remarketers to serve advertisements on our behalf across the internet and for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Website and elsewhere on the web. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Websites and other sites, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Website and other sites, and better understand your online activity. 

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By accessing and using the Services, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

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We may also work with third-party social media sites, such as Facebook, Google, and other media platforms, to serve ads to you as part of a customized campaign, unless you notify us that you prefer not to have information about you used in this way. For more information about how you can opt out of customized campaigns, please see “Your Choices” below.

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d. As part of the sale or other transfer of our business

As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event, Your Data may be part of the transferred assets.

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e. For legal purposes

To the extent permitted by law, we may also disclose Your Data when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of GGV or others. We may also share Your Data to: (i) satisfy any applicable law or regulation, (ii) investigate and defend ourselves against any third-party claims or allegations, or (iii) protect against harm to the rights, property or safety of us, the Website, other Website users, or third parties.

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f. Affiliates

We may share Your Data with our affiliates for the purposes noted above or otherwise in this Policy.

4. Children’s Privacy 

GGV takes children’s privacy seriously. We do not seek to collect personal information about children under the age of 13 through our Website or Services. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Privacy Policy by instructing their children to never provide us personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will promptly take steps to delete such information and terminate the child’s account.

5. External Websites 

The Services may contain links to third-party websites. GGV has no control over the privacy practices or the content of any of our business partners, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites. 

6. Security 

We take commercially reasonable steps to protect Your Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

7. Your Choices

a. Deletion of Information

If you would like us to delete any or all personal information or “private” information you have provided to us, please email us at privacy@ggvc.com. To the extent compatible with our legal or regulatory record keeping requirements, we will use commercially reasonable efforts to process such requests in a timely manner.

b. Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Website. For additional information on how to opt-out of the use of cookies or beacons, click on the following link: 

https://www.networkadvertising.org/choices/ and https://www.aboutads.info/choices/. You may also be able to opt-out of receiving cookies through the Digital Advertising Alliance in the USA, the Digital Advertising Alliance of Canada in Canada, or the European Interactive Digital Advertising Alliance in the European Union. 

c. Promotional Communications

You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at privacy@ggvc.com.

d. Disable Certain Data Sharing

You can limit how we share your data with our marketing partners to more effectively market our brand, products and services to you on our Website and across other sites and applications by contacting us at privacy@ggvc.com. When disabled, we will no longer share personal information with these partners for these purposes.

8. Do Not Track

As discussed above, third parties such as advertising networks and analytics providers may collect information about your online activities over time and across different websites when you access or use the Services. Currently, various browsers offer a “Do Not Track” option, but there is no standard for commercial websites. At this time, we do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

9. Notice to California Residents

If you are a resident of the state of California, you should review our CCPA Notice at the end of this document, where we discuss additional rights you may have with respect to your personal information under California law.

10. Notice to Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at privacy@ggvc.com, the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. 

11. Notice to Non-U.S. Residents

The Site and the Services are hosted in and provided from the United States and are intended for visitors located within the United States. 

If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States where the privacy laws may not be as protective as those in your country of origin. If you are located outside the United States and choose to use the Services, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy, and you do so at your own risk.

12. Updates to This Privacy Policy 

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may update this Privacy Policy from time to time and without prior notice to you to reflect changes in our privacy practices. We will indicate at the top of this Privacy Policy when it was most recently updated, and we encourage you to revisit this page periodically to stay aware of any changes. By accessing the Services after we notify you of changes to this Privacy Policy, you are deemed to have accepted such changes. 

13. How to Contact Us

If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights and choices, please email us at privacy@ggvc.com.

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On January 1, 2023, the California Privacy Rights Act (“CPRA”) replaced the California Consumer Privacy Act, which had been in effect since 2020. 

This California Privacy Rights Act Notice (the “CPRA Notice”) supplements our Privacy Policy and applies to the Personal Information of residents (referred to as “consumers”) and households located in the State of California that is collected by or on behalf of GGV (online and/or offline). All defined terms herein have the meanings given in the CPRA, or in the Privacy Policy. If GGV is processing your Personal Information as a service provider or contractor, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.

In the event of any conflict between this CPRA Notice and terms in the Privacy Policy, the provision that is more protective of your Personal Information shall control to the extent of such conflict. If you have any questions about this CPRA Notice or whether any of the following rights apply to you, please contact us at privacy@ggvc.com with the subject line “CPRA Request.”

I. Your Rights and Choices

The CPRA provides consumers and households with specific rights regarding their Personal Information. This section describes these rights and explains how to exercise them.

1. Right to Know About Your Personal Information 

You have the right to request that we disclose the following kinds of information to you about our collection, disclosure, sale and use of your Personal Information:
 

• The categories of Personal Information we have collected about you;
• The categories of sources from which we have collected the Personal Information;
• The business or commercial purpose for collecting, selling, or sharing your Personal Information;
• The categories of third parties with whom we have shared your Personal Information;
• The categories of Personal Information that we have sold, and for each category identified, the categories of third parties to whom we have sold that particular category of Personal Information;
• The categories of Personal Information that we have disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Information; and
• The specific pieces of Personal Information we have collected about you after January 1, 2022, unless doing so is impossible or would involve disproportionate effort.
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a. Categories of Personal Information We Collect, Disclose, Sell and Share

We do not sell Personal Information obtained about you to any third parties and have not done so in the twelve (12) months preceding the effective date of this CPRA Notice. 

We have or might have collected, disclosed, or shared Personal Information as follows:

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• Categories of Personal Information: We have or might have collected or otherwise obtained the categories of Personal Information from or about consumers and their devices that are referenced in the section of our Privacy Policy titled “Information We Collect.”
• Categories of Sources: We have or might have collected the categories of Personal Information listed above from the categories of sources referenced in the section of our Privacy Policy titled “Information We Collect.”
• Categories of Business or Commercial Purposes: We collect the categories of Personal Information listed above for the business or commercial purposes referenced in the section of our Privacy Policy titled “How We Use Your Data.”
• Categories of Third-Party Recipients: We have or might have disclosed the categories of Personal Information listed above to the third-party recipients referenced in the section of our Privacy Policy titled “How We Share Your Data.”
• Categories of Personal Information Shared: We have or might have shared the following categories of Personal Information with the following third parties:

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You have the right to opt out of this disclosure of your information. For information on how to do so, please see Section II below.

• Categories of Personal Information Disclosed for a Business Purpose: We have or might have disclosed the categories of Personal Information we collect to the above-mentioned third-party recipients in connection with the usage described in the “How We Use Your Data” section of the Privacy Policy and for the following business purposes:

b. Specific Pieces of Personal Information

If you would like to know the specific pieces of Personal Information we have collected about you, please contact us as described in Section II (“Exercising Your Privacy Rights”) below, and we will provide you with the information collected on or after January 1, 2022. You may exercise this right up to two times in any 12-month period.

c. Data Retention Periods

We only keep the Personal Information we have about you for as long as required under the law or as needed for the business purposes described above. If you have any questions or concerns about our data retention practices, please do not hesitate to reach out to us.

2. Right to Request Deletion

You may have the right to request deletion of your Personal Information. We will honor such request, but might not be able to fulfill your request if we (or our service providers) are required to retain your Personal Information. Examples of such exceptions are:

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• Completing a transaction or performing a contract we have with you; 
• Detecting and addressing data security incidents, and repairing or upkeep of our IT systems;
• Protecting against fraud or other illegal activity; 
• Complying with applicable law or a legal obligation, or to exercise rights under the law (e.g. the right to free speech); or
• Using your Personal Information internally to improve our Services.

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3. Right to Request Correction

You may have the right to request that we correct inaccurate Personal Information that we maintain about you. We will honor such request, but might not be able to fulfill your request if it is impossible to do so or would involve disproportionate effort, or if we have a good-faith, reasonable, and documented belief that a request to correct is fraudulent or abusive.

4. Right to Opt-Out of the Sale or Sharing of Personal Information

You may have the right to opt-out of the sale or sharing of Personal Information. Please note that while we do not “sell” your Personal Information, and have not done so in the past, we may, as described above, “share” your Personal Information with third parties for cross-context behavioral advertising. If you wish to opt-out of such sharing, please contact us as described in Section II (“Exercising Your Privacy Rights”) below.

5. Right to Limit the Use and Disclosure of Sensitive Personal Information

You may have the right to limit the use and disclosure of sensitive Personal Information. Please note that we do not collect sensitive Personal Information in the context of providing the SMBTech 50 List, and have not done so in the past.

6. Right to Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights. We will not (i) deny you products or services, (ii) charge you different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties (except for financial incentives permitted by the CPRA, see below), (iii) provide you a different level or quality of products or services, and (iv) suggest that you may receive a different price or rate for products or services or a different level or quality of products or services. 

7. Right to Designate an Authorized Agent

If you submit a request to know or delete your Personal Information through the use of an authorized agent, we may require that you (i) provide the authorized agent written permission to act on your behalf, and (ii) verify their identity directly with us. We may deny a request from an authorized agent that does not submit proof of authorization.

II. Exercising Your Privacy Rights

To exercise the rights described above, please submit a request to us by email at: privacy@ggvc.com.

III. What We Need to Know to Fulfill Your Request

The request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information related to you. Making a request does not require you to create an account with us. 

Typically, we will ask that you match specific pieces of information you have provided us previously, as well as, in some instances, provide a signed declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. For requests related to particularly sensitive information, we may require additional proof of identification. If you make a request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. 

IV. How You Will Hear Back from Us

We will confirm receipt of a request within then (10) business days of its receipt and endeavor to respond within forty-five (45) calendar days of its receipt. If we require more time, we will notify you of the extension and provide an explanation of the reason for the extension in writing, and we will provide you with a response no later than ninety (90) calendar days of receipt of the request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

We may charge a reasonable fee to process or respond to your requests if they are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for this decision and provide you with a cost estimate before completing your request.

V. Other California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of Personal Information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. In order to submit such a request, please contact us at privacy@ggvc.com. Please note, however, that we do not disclose Personal Information to third parties for such third parties’ direct marketing purposes.

VI. Changes to this CPRA Notice

This CPRA Notice is effective as of the date of the “Last Update” stated at the top of this CPRA Notice. We may change this CPRA Notice from time to time with or without notice to you. By visiting or accessing the Sites or the Services, or otherwise engaging or interacting with us after we make any such changes to this CPRA Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your Personal Information is governed by the CPRA Notice in current effect. Please refer back to this CPRA Notice on a regular basis. 

VII. Contact Information

If you have any questions or comments about this CPRA Notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: 

Mailing Address: 

3000 Sand Hill Road

Building 4, Suite 230

Menlo Park, CA 94025

Email Address: privacy@ggvc.com

Phone Number: (650) 475-2150