Privacy Policy

Thank you for visiting the websites owned and operated by True Venture Management, LLC (“we,” or “us”), which may include https://trueventures.com/, https://www.trueventures.ai/, https://trueventures.polsia.app/, our invitation-only community platform True Connect at https://connect.trueventures.com or other True Ventures websites that link to these Terms of Use (collectively, the “Sites”, together with all products, services and applications made available therein, the “Services”). We respect your privacy and, whether you are visiting the Sites as an investor, founder or member of the general public or otherwise using the Services, you are entitled to the protection of your personal information.

By using or accessing our Services in any manner, including when interacting with the True Connect platform, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of the Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy.

1. What this Privacy Policy Covers

This Privacy Policy covers important information and disclosures relating to how we treat Personal Data that we gather when you access or use our Services, but does not cover the practices of companies we don’t own or control or people we don’t manage, nor to the privacy practices of any entity with whom we have an investment relationship, even if you are able to access such entity’s website or service through a link on the Sites. It also does not apply to information obtained or disclosed in offline correspondence or in connection with an investment in one of our affiliated investment funds.

Residents of California or the European Economic Area (“EEA”) or the United Kingdom (“UK”) should refer to the relevant subsections below. If you have a disability, you may access this Privacy Policy in an alternative format by contacting legal@trueventures.com.

2. Categories of Personal Data We Collect

We collect the following categories of Personal Data over the past 12 months:

Profile or Contact Data

• First and last name
• Email
• Mailing address
• Phone number
• User or Session ID
• True Connect Account Credentials
• Social media profiles

Device/IP Data

• IP address, device ID, domain server
• Browser name, browser location (city, state, country)
• Platform / operating system, URL
• Type of device/operating system/browser used to access the Services

Web Analytics

• Web page interactions
• Referring webpage/source through which you accessed the Services
• Non-identifiable request IDs
• Statistics associated with the interaction between device or browser and the Services

Messaging Analytics

• Message identifiers such as group ID, group name, message or reply IDs or subjects
• Source used to access messages or links (i.e. email, browser, etc.)
• Message and link clicks and opens

Other Identifying Information You Voluntarily Choose to Provide

• Identifying information in emails or letters you send us
• Survey responses including gender identity, race or ethnicity, educational information, limited health information, or work-related information including company, industry, location preferences, personal statement, resume, pitch deck and/or video submissions
• Content and User Submissions you provide to the Services, including the True Connect platform — posts, comments, and messages with other users
• Conversational inputs, questions, prompts, and other information you submit when interacting with AI-powered features or avatars (e.g., True AI Office Hours); startup or business information you choose to share in AI conversations; model or platform preferences selected when using AI-personalized content features (e.g., True North)

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You — when you provide information directly: when you use our Services, voluntarily fill in free-form text boxes or surveys, send us an email, post or comment in True Connect, interact with AI features or avatars, or select a third-party AI platform to personalize content. Also collected automatically through Cookies (see Tracking Tools below).

Third Parties — analytics providers help us analyze how you interact with the Services; third parties may help auto-populate True Connect member profiles, including profile display photos or avatars.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, customizing and improving the Services: providing you with the products, services, or information you request; meeting or fulfilling the reason you provided the information to us; providing support and assistance; improving the Services through testing, research, internal analytics and product development, including via AI Tools; personalizing the Services and communications based on your preferences; fraud protection, security, and debugging.

Corresponding with you: responding to your correspondence, contacting you when necessary, and sending information about us or the Services according to your preferences.

Meeting legal requirements and enforcing legal terms: fulfilling our legal obligations, protecting rights/property/safety, enforcing agreements, responding to claims of third-party rights violations, resolving disputes.

3. How We Share Your Personal Data

We disclose your Personal Data to the following categories of recipients:

Service Providers

Hosting, technology and communication providers; security and fraud prevention consultants; analytics and platform-management providers (which may rely on AI/ML); AI model and avatar providers that power conversational AI features on the Sites including True AI Office Hours; support and customer service vendors.

Business Partners

Businesses that you have a relationship with, including our investment fund affiliates.

Parties You Authorize, Access or Authenticate

Third parties you access through the services. Other users of the True Connect platform.

Legal Obligations

We may share Personal Data with third parties in connection with legal compliance and enforcement activities described above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business. We will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies.

Data That Is Not Personal Data

We may create aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, provided that we will not share such data in a manner that could identify you.

True Connect Platform Content

Content and User Submissions you submit to the True Connect platform will be accessible to the broader True Connect community. When you post, comment, or message inside True Connect, other visitors and users will see that content, the username associated with it, and the date/time it was submitted.

Your True Connect account has a profile page viewable by other True Connect members. It may include your username, prior posts and comments, profile display name, profile display photos or avatars, about section, social links, membership tenure, and other related information.

4. Tracking Tools and Opt-Out

The Sites use cookies and similar technologies (pixel tags, web beacons, clear GIFs and JavaScript — collectively, “Cookies”) to recognize your web browser, analyze trends, learn about our user base, and operate and improve our Services. Because of our use of Cookies, the Sites do not support “Do Not Track” requests sent from a browser at this time.

Essential Cookies

Required for providing features or services that you have requested (e.g., logging into secure areas). Disabling these may make certain features unavailable.

Functional Cookies

Record your choices and settings, maintain preferences over time, and recognize you when you return.

Performance/Analytical Cookies

Help us understand how visitors use the Sites — number of visitors, pages viewed, time spent. Also help us measure advertising campaign performance.

You can decide whether to accept Cookies through your browser’s settings. Most browsers offer an option for turning off Cookies or deleting Cookies that are already on your device. To explore options, look in the “preferences” or “options” section of your browser’s menu. For more on Cookies, visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.

5. Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, and administrative security measures. The Sites use industry standard SSL technology to encrypt Personal Data you provide.

We retain Personal Data about you for as long as necessary to provide our Services to you, comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law. We may further retain information in an anonymous or aggregated form. When you delete your account, your profile remains visible to other users as an “Alumni” account and the posts, comments, and messages you submitted prior to deleting your account will still be visible to others.

No method of transmitting or storing data over the Internet is completely secure. Except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

6. Personal Data of Minors

We do not knowingly collect or solicit Personal Data about children under 16 years of age, except with parental consent. If you believe that a child under 16 may have provided Personal Data to us, please contact us at legal@trueventures.com.

7. Privacy Rights of California Residents

If you are a resident of California, you have the rights set forth in this section.

Access

You have the right to request information about our collection and use of your Personal Data over the past 12 months: the categories collected, specific pieces, the categories of sources, business purpose, and the categories of third parties with whom we’ve shared it.

Deletion

You have the right to request that we delete the Personal Data we have collected about you, subject to certain exceptions under the CCPA.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you, subject to certain exceptions under the CCPA.

Exercising Your CCPA Rights

To exercise these rights, send a request that (1) provides sufficient information for us to verify your identity and (2) describes your request in sufficient detail. Submit a Valid Request by emailing us at legal@trueventures.com. We will work to respond within 45 days. You may also authorize an agent to exercise your rights on your behalf with written permission.

We Do Not Sell Your Personal Data

We will not “sell” your Personal Data, as that term is defined in the CCPA, and have not done so over the last 12 months. We do not sell the Personal Data of minors under 16.

Personal Data Sharing Opt-Out and Opt-In

We will not share your Personal Data for cross-contextual behavioral advertising and have not done so over the last 12 months.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not deny you access to our Services or provide a lower quality of services if you exercise your CCPA rights.

8. Privacy Rights of Other United States Residents

California Resident Rights

California residents may contact us to prevent disclosure of Personal Data to third parties for direct marketing purposes under California Civil Code Sections 1798.83-1798.84. To submit a request, contact legal@trueventures.com.

Nevada Resident Rights

Nevada residents have the right to opt-out of the sale of certain Personal Data. Contact us at legal@trueventures.com with the subject line “Nevada Do Not Sell Request”. We do not currently sell your Personal Data as defined in Nevada Revised Statutes Chapter 603A.

9. Privacy Rights of EEA and UK Residents

Our Services are hosted and operated in the United States. If you are a resident of the EEA or UK, you may have additional rights under the GDPR. By using the Services, you authorize us to transfer, store, and process your information in the U.S.

Legal Basis for Processing

We process your Personal Data based on contractual necessity, our legitimate interests, your consent, or other legal grounds.

EU Data Subject Rights

• Access — request information about and a copy of your Personal Data
• Rectification — correct or supplement your Personal Data
• Erasure — request deletion of some or all of your Personal Data
• Withdrawal of Consent — withdraw consent at any time
• Portability — receive a copy of your Personal Data in machine-readable format
• Objection — object to further use or disclosure for certain purposes
• Restriction of Processing — restrict further processing of your Personal Data
• Right to File Complaint — lodge a complaint with the supervisory authority of your country or EU Member State

For more information about these rights or to submit a request, contact us at legal@trueventures.com.

10. Changes to This Privacy Policy

We may need to change this Privacy Policy from time to time. We will alert you to any such changes by placing a notice on our Sites, by sending you an email and/or by some other means. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

11. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please contact us at legal@trueventures.com.