Privacy Policy

Effective Date: June 30, 2020

Mayfield values your privacy. This Privacy Statement (“Statement”) describes how we may collect, use, share and otherwise process Personal Information we collect through our websites at www.mayfield.com, careers.mayfield.com, and events.mayfield.com (collectively the “Websites”), as well as information that we may collect via other means (including offline), as described below. Mayfield consists of a collection of investment funds and other entities. Our Websites are maintained and operated by Mayfield Fund, L.L.C. (which is a back-office and administrative service entity within Mayfield) and in some cases, by or in collaboration with a third party. In accordance with industry custom, this Website occasionally uses terminology that may be interpreted to suggest that Mayfield is actually a single entity. However, there is no such single entity and all of the entities that comprise Mayfield have their own separate legal existence.

Some regulators such as the Securities and Exchange Commission and the Federal Trade Commission have adopted rules that may require financial institutions, like Mayfield, to provide privacy policy notices to their clients. If you are a natural person who invests with us, the privacy policy notice that you receive with your investment materials will govern how we use your personal data. Additionally, this Privacy Notice does not apply to employees, applicants for employment, or contractors, who receive a separate notice about our privacy practices, or to business contacts.

Information We Collect
When we use the term “Personal Information” we mean any kind of information that allows us to identify you, directly or indirectly, such as your name, contact details, or address, or any other information that relates to an identifiable person. We may collect and process the following Personal Information about you:

1. Personal Information you provide to us
We collect Personal Information directly from you both online and offline. This includes from:

• Forms you complete (or which are completed by your authorized representatives on your behalf) on the Websites or otherwise; and
• Your correspondence and interactions with us, including by letter, email and telephone.

The information we collect from you may include the following categories of Personal Information:

• Identifiers, such as your name, address, email address and telephone numbers;
• Professional or employment information, such as your job title and place of work;
• Commercial information, such as payment history;
• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including financial information; and
• Other information you provide.

2. Personal Information We Collect Automatically
Mayfield may, but has no obligation to, monitor and record activity on our Websites for any reason. Mayfield may collect “tracking information” about your visit, including the pages you view, the links you click, and other actions taken in connection with Mayfield’s Websites and services. Mayfield also collects certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times, and referring website addresses.

When you receive newsletters or promotional e-mail from Mayfield, we may use web beacons, customized links, or similar technologies to determine whether the e-mail has been opened and which links you clicked, in order to provide you with more focused e-mail communications or other information.

The information we collect automatically may include the following categories of Personal Information:

• Identifiers, such as IP address or other online identifiers; and
• Internet or other electronic network activity information, including, but not limited to, information regarding your interaction with our Websites.

3. Personal Information collected from third parties
We may collect Personal Information about you from third parties, such as business partners, vendors, or from publicly available information. The conditions under which we may obtain such information are governed by the third party source.
The information we collect from you may include the following categories of Personal Information:

• Identifiers, such as your name, address, email address and telephone numbers;
• Professional or employment information, such as your job title and place of work;
• Commercial information, such as payment history; and
• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including financial information.

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In order to offer you a more consistent and personalized experience in your interactions with Mayfield, information collected through one Mayfield service may be combined with information obtained through other Mayfield services.

The Way We Use Information
Broadly speaking, we use Personal Information and other information for purposes of conducting our business and investment activities, delivering newsletters to subscribers, delivering information to our investors, providing customer service, providing registration for events sponsored by Mayfield, facilitating job applications on behalf of our portfolio companies, and making available other products and services. Additionally, we may use information that we collect for marketing and promotions and to improve our marketing and promotional efforts, to understand their usage trends and preferences on our Websites, to improve the way our Websites work and look, and to create new features and functionality. We may also use Personal Information to protect our rights and interests, ensure the security of our assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, enforce our terms and conditions; and where required by applicable U.S. federal, state or local, or non-U.S., law, rule, regulation, executive order or policy (“Applicable Laws”), including laws relating to know-your-client requirements, tax, the prevention of money laundering, fraud, terrorist financing and sanctions or where our processing is necessary for the establishment, exercise or defense of legal claims.

Personal Information collected via our Websites and services may be stored and processed in the United States or any other country in which Mayfield or its affiliates, subsidiaries, or agents maintain facilities.

Notwithstanding any provision of this Statement to the contrary, except as we have otherwise agreed to in a binding written agreement, we reserve the right to use any information in any manner permitted or required by Applicable Laws.

Sharing of Your Information
Except as otherwise noted in this Statement, we generally do not share Personal Information with third-parties unless we believe doing so is appropriate in connection with the management or operation of our investment funds, or to carry out a request from you, or we reasonably believe that doing so is legally required or is in our interest to protect our property or other legal rights or the rights or property of others.

We may disclose Personal Information to:

• Our affiliates, service providers and relevant counterparties without your consent, or as required by Applicable Laws;
• Any governmental agency, regulatory authority or self-regulatory organization having jurisdiction over Mayfield or its affiliates, if (i) Mayfield determines that such disclosure is necessary or advisable pursuant to or in connection with any Applicable Laws, including without limitation any anti-money laundering law and the USA PATRIOT Act and (ii) such disclosure is not otherwise prohibited by Applicable Laws;
• Persons acting in a fiduciary or representative capacity on behalf of an investor, such as an IRA custodian or Trustee of a grantor trust; and
• Certain other persons to the extent authorized by you.

If Mayfield were to sell its assets, merge with another entity or file for bankruptcy, information collected from our Websites generally would be a Mayfield asset and may be transferred.

We do not share Personal Information with other, third-party organizations for their marketing or promotional use without your consent.
Mayfield does not sell or rent Personal Information to third-parties, and has not done so over the 12-month period preceding the effective date of this Statement.

Accessing Your Personal Information
You may have the ability to view or edit your Personal Information online. In order to help prevent your Personal Information from being viewed by others, you will be required to sign in with your credentials (user ID/name and password). The appropriate method(s) for accessing your Personal Information will depend on which sites or services you have used.

Security of Your Personal Information
Mayfield is committed to protecting the security of your Personal Information. Nevertheless, no data transmitted over (or connected to) the Internet can be guaranteed to be 100% secure. Electronic communications can be intercepted by third-parties and accordingly, transmissions to and from our Websites may not be secure. We cannot ensure or warrant the security of any information you transmit to us, therefore you do so at your own risk. Once we receive your transmission, we take steps to ensure security on our systems. We use secure server software (SSL) and firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such firewalls and secure server software.

A password is used to help protect Personal Information. It is your responsibility to keep your password confidential. Do not share this information with anyone. If you are sharing a computer with anyone, you should always choose to log out before leaving a site or service to protect access to your information from subsequent users.

Children
Consistent with the United States Children’s Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without requiring parental consent. Any person who provides their Personal Information to Mayfield through our Websites represents that they are 13 years of age or older.

California Shine the Light Law
If you are a California resident, you have the right to request information about how we share certain categories of Personal Information with third parties. California law gives you the right to send us a request at a designated address to receive the following information:

• Categories of information we disclose to third parties for their direct marketing purposes during the preceding calendar year; and
• Names and addresses of the third parties that received that information; and, if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

Use of Cookies
Our Websites use “cookies” to gather general information about the browsing activities of visitors to our Websites.  This allows us to constantly improve the Websites’ design by arranging the content in the most user-friendly manner and to continually meet the users’ needs. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. (Nevertheless, we cannot guarantee that cookies will not be accessed by other persons.)

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of Mayfield sites that depend on cookies. To learn more about how to manage cookies on different types of browsers, you can visit the website www.allaboutcookies.org.

Use of Web Beacons
Mayfield web pages may contain electronic images known as “web beacons” – sometimes called single-pixel gifs – that may be used to assist in delivering cookies on our sites and that allow us to count users who have visited those pages as well as deliver co-branded services. We may include web beacons in promotional e-mail messages or our newsletters in order to determine whether messages have been opened and acted upon.

Mayfield may also employ web beacons from third-parties in order to help us compile aggregated statistics and determine the effectiveness of our promotional campaigns. It is our policy to prohibit web beacons on our sites from being used by third-parties to collect or access your Personal Information.

“Do Not Track” Browser Settings
We do not currently use technology that recognizes “do not track” signals from your web browser.

Other Web Sites Linked to from Our Websites
Some Mayfield services, such as provided on our careers.mayfield.com and events.mayfield.com websites, may be co-branded and offered in conjunction with another company. If you register for or use such services, both Mayfield and the other company may receive Personal Information collected in conjunction with the co-branded services. You should carefully review that other company’s privacy statement for information about their privacy practices.

We are not responsible for the practices employed by websites linked to from our Websites nor the information or content contained therein. Please remember that when you use a link to go from our Websites to other websites, this Statement does not apply to such other websites. Mayfield is responsible only for the content of our Websites and has no control over other websites that may be accessible from our Websites, the contents therein, or the products/services offered thereby. Links to those websites do not imply any endorsement of those websites or the information or materials available at those websites. If you access any third-party website through our Websites or otherwise, you do so at your own risk. Your browsing and interaction on any other website, including a website which has a link on our Websites, are subject to that other website’s own rules and policies. Please read those rules and policies before proceeding.

Automated Decisions
We will not use Personal Information to formulate a decision based solely on automated processing which produces legal effects or similarly significantly impacts the person.

Privacy rights
We are committed to providing individuals with reasonable and appropriate access to their Personal Information. If you believe that we are processing Personal Information about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as where the request is manifestly unfounded or excessive. We are happy to correct inaccurate data or delete information that is not appropriate to retain. Please also let us know if you have any questions, concerns, disputes, or issues.

Individuals in Andorra, Argentina, Australia, California, Canada, Cayman, Europe, Faroe Islands, Guernsey, Hong Kong, Israel, Isle of Man, Japan, Jersey, Mexico, New Zealand, Singapore, South Korea, Switzerland, the United Kingdom, Uruguay, and certain other jurisdictions may have certain data subject rights. These rights vary, but they may include the right to: (i) request access to and rectification or erasure of their Personal Information; (ii) restrict or object to the processing of their Personal Information; and (iii) obtain a copy of their Personal Information in a portable format. Individuals may also have the right to lodge a complaint about the processing of Personal Information with a data protection authority. We are always open to dialogue to resolve issues short of formal disputes. If your concerns cannot be resolved, we can enter into appropriate third-party neutral dispute resolution. If you need to reach us about a privacy or data protection issue, please contact us using the details below.
If you wish to exercise any of these rights please contact us using the information provided below in the section, Contacting Us. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a data subject rights request.

We do not discriminate against you, for exercising any of these rights.

If you make a request related to Personal Information about you, we will need to verify your identity. To do so, we will request 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. We will process your request within the time provided by Applicable Laws.

Additionally, under California Civil law, Californians are entitled to request information relating to whether a business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. Californians who wish to request further information about our compliance with this statute or who have questions, more generally, about our Privacy Statement and our privacy commitments and our Websites should contact us using the information provided below in the section, Contacting Us.

Modifications of These Terms
Mayfield reserves the right, at its discretion, to change, modify, add, or remove portions of this Privacy Statement at any time. When Mayfield does so, it will also revise the “effective date” at the end of these Terms. Please check these Terms periodically for changes.

Contacting Us
Any questions, concerns, or complaints regarding this Privacy Statement should be sent to:

By email: info@mayfield.com

By mail:
c/o Information Technology Department
Mayfield Fund, L.L.C.
2484 Sand Hill Road, Menlo Park, California 94025.

By Phone: 1-866-479-4777 or 1-650-233-5766

Effective Date: June 30, 2020