Vincent Privacy Policy

Privacy Policy

Last Updated November 14th, 2023

Vincent Labs, Inc. and its affiliates and subsidiaries (collectively, “Vincent”, “we”, “our” or“us”) are committed to protecting your privacy. Vincent may collect information relating to you as an individual including certain sensitive personal information, where permitted by law (your “personal information”). This privacy policy (the “Privacy Policy”) describes the ways in which we collect information from you, including specifically when you use our website (“Website”), and what we may use it for. This Privacy Policy also applies to our collection and use of information in the normal course of business. This Privacy Policy is at all times subject to any applicable requirements of local law and regulation.

This Privacy Policy describes:

What personal information we collect about you
How we obtain your personal information
How we use your personal information
On what basis we use your personal information
How long we keep your personal information
Who we share your personal information with
How we protect your personal information
Which countries we transfer your personal information to
Your rights regarding your personal information

Contact

If you have any questions or comments regarding this Privacy Policy or the processing of your personal information byVincent, please contact help@withvincent.com.

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What personal information do we collect about you?

We may collect personal informationfrom you in the course of our business, including through your use of our Website,by our useof cookies, and when you contact or request information from us. Much of that data comprises business information, but some of that data may inevitably comprise your personal information. The personal information we may collect and use includes:

name and contact details (including email addresses, titles and other business information);
logs of emails and internet use, including your use of the Website;
technical information, such as information from your visits to our Website or applications or in relation to materials and communications we send to you electronically;
information you provide to us for the purposes of attending meetings and events;
identification and background information provided by you or collected as part of our business acceptance processes;
personal information provided to us by you or on your behalf or generated by us in the course or providing services, which may include special categories of data; and
any other information relating to you which may be provided to us.

How we obtain your personal information

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We collect information or data from you in various ways, including:

during the course of your use of the Website (this will include any and all material you send or submit either to the Website or to any email address provided on the Website);
by our use of “cookies” (see “Use of Cookies”);
information which you provide to us and when we request further information from you from time to time;
as part of our business acceptance processes and about you and others as necessary in the course of providing services;
while monitoring our technology tools and services, including our Websites and email communications sent to and from Vincent;
when you provide it to us, or interact with us directly, for instance engaging with our employees or signing up or registering on any of our digital platforms or applications to participate in our events or subscribing to our newsletters or publications;
from providers of compliance-related information or credit-related information; and
from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.

How we use your personal information

We collect and use data collected from you (however collected), including any personal information, for the following legitimate business purposes of Vincent:

administration and functionality of our Website, any digital platforms and applications;
to process your requests and answer your inquiries;
the continuation of Vincent’s business and the provision of services;
to fulfill the purpose for which you provided the information;
provision of information regarding alternative investments, Vincent, and our services, events, seminars and publications, our marketing information and all other information or materials offered by us;
sending of newsletters, industry updates and all other information or materials offered by us;
consolidation of information relating to our customers, subscribers, and vendors among Vincent affiliates and subsidiaries;
monitoring, support, analysis and improvement of our services;
to engage in marketing and advertising activities, provided that, where required under applicable law, we will obtain your prior opt-in consent;
to understand general trends and patterns so we can develop and support existing and ongoing marketing strategies for our products and services;
to engage in research, project planning, troubleshooting, and detecting and protecting against error, fraud, or other criminal activity;
to disclose aggregated, anonymous, user statistics and other information to agents, business partners and other third parties for lawful purposes;
to share some or all of your information with our affiliates or subsidiaries;
to fulfill legal and regulatory requirements and to comply with applicable law, including compliance with subpoena, lawful court order, or similar legal process, and when we believe in good faith that disclosure is necessary to protect and pursue our rights, resolve disputes, protect your safety or the safety of others, investigate fraud, or respond to a government request;
to assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment or similar corporate event where we expect that your personal information will be part of the transferred assets; and
matters incidental to the purposes of use set out above, where permitted by applicable local law and regulation.

You may use the Website without providing us with your personal information. However, some features on the Website allow you to provide us voluntarily with personal information. If the provision of your personal information is mandatory for a specified purpose, we will let you know that this is the case and inform you of the consequences of failure to provide such personal information.

Subscriptions tonewsletters

In order to subscribe to a newsletter or attend events hosted by us, such as webcasts, the following information maybe required: first name; last name; email address; company name, title, city and country. If the required data is not supplied,the newsletter or events will not be made available to you.

Meetings, events and seminars

We will collect and process personal information about you in relation to your attendance at an event or seminar organized by Vincent or its business partners. We will only process and usespecial categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organizing or hosting the relevant event.

Other services

We collect, create, hold and usepersonal information in the course of and in connection with the services weprovide to our users. We will process identification and background informationas part of our business acceptance, finance, administration and marketingprocesses, including anti-money laundering, reputational and financial checks.We may also process personal information provided to us by you or on your behalffor the purposes of providing our products or services to you. The informationmay be disclosed to third parties to the extent we think it is reasonablynecessary in connection with provision of our products or service. Please alsosee “Who we share your personal information with” and “Which countries wetransfer your personal information to” below.

Marketing and related communications

If you have already signed up orsubscribed to receive materials from us, we may use your personal informationin order to send you electronic materials relating to Vincent or alternativeinvestments, our newsletters and other products and services and to updaterecords held by us. If you are not already signed up or subscribed to receive informationor materials from us and wish to do so, or if you wish to subscribe toadditional publications, please sign up here using this link.

You may withdraw your consent to thereceipt of materials or newsletters at any time and free of charge by clickingon the “unsubscribe” link in the email, or by sending an e-mail to help@withvincent.com.

Business re-organization

Vincent may in the future re-organize or transfer all or part of its business which may result in the transfer of your personal information to new entities (which will be subsidiaries or affiliates of Vincent) or third parties through which the whole or part of the business of Vincent will be carried out. If Vincent ceases to trade, or becomes insolvent, enters into receivership or any similar or equivalent event occurs, those acting on behalf of Vincent may sell the business or partsof it to a third party, in fulfillment of legal or business requirements. This may result in the transfer of your personal information to a third party through which the business or parts of it will be carried out.

On what basis we use your personal information

We use your personal information onthe following bases:

to perform a contract, such as engaging with an individual to provide certain services;
for the establishment, exercise or defense of legal claims or proceedings;
to comply with legal and regulatory obligations; and
for legitimate business purposes. Please see “How we use your personal information” for more details.

How long we keep your personal information

Vincent endeavors to ensure thatpersonal information is kept up-to-date and that irrelevant, excessive orout-of-date personal information is updated or deleted. To determine theappropriate retention period for your personal information, we will considerthe amount, nature and sensitivity of the personal information, the potentialrisk of harm from unauthorized use or disclosure of your personal information,the purposes for which we process the personal information and whether we canachieve such purposes through other means, the applicable legal and regulatoryrequirements (including requirements to retain the personal information for aminimum period), limitation periods for taking legal action, good practice and Vincent’sbusiness purposes.

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Who we share yourpersonal information with

Sharing data to third parties

Personal information may be shared with other non-affiliated third parties, including:

service providers which perform certain services on behalf of Vincent, pursuant to our direction, or as directed or consented to by you, if applicable;
third parties engaged in the course of the services we provide, such as technology service providers;
third parties involved in hosting events;
auditors and professional advisors; and
regulatory authorities, courts and tribunals, government agencies and law enforcement agencies (such as the police).

Vincent may use social media sites such as Facebook, LinkedIn and X (formerly known as Twitter). If you use these services, you should review their privacy policies for more information on how they deal with your personal information.

We may share or otherwise makepersonal information available to our affiliates and subsidiaries forcommercial use in their business activities and operations.

We will not sell, rent, distribute orotherwise make personal information commercially available to any third partyexcept with your prior permission.

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How we protect yourpersonal information

We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection laws.

Which countries we transfer your personal information to

The Internet is a global environmentand Vincent’s principal place of business is in the United States of America.In certain circumstances, we may need to transfer personal information tolocations outside the local jurisdiction in which you are viewing the Websiteand process personal information outside that jurisdiction for the purposes setout in this Privacy Policy.

International transfers tothird parties

Some of the third parties to whom wemay transfer your personal information for the purposes described above may belocated in countries or territories which are outside your local jurisdictionand specifically outside the EEA and the United Kingdom. The data protectionand privacy laws in those jurisdictions may not provide for the same level ofprotection of your personal information as exists in your home country or inthe EEA.

Security of electroniccommunications

Please note that any electroniccommunication made between you and us, including via the Website, may not besecure. While we welcome you to contact us, please do not send us anyelectronic communication that contains any confidential or sensitive personalinformation or data.

Your rights regardingyour personal information

Subject to the provisions of locallaws and regulations from time to time, you may be entitled:

to object, on grounds relating to your particular situation and subject to certain conditions, to the processing of your personal information;
to request confirmation as to whether Vincent has personal information relating to you;
to access the personal information about you being processed by Vincent and to obtain certain information about the processing of that personal information;
to require Vincent to rectify any inaccurate or incomplete personal information about you;
to require Vincent to erase personal information about you in certain circumstances, subject to compliance with any applicable data retention obligation;
to restrict Vincent from processing personal information about you in certain circumstances;
to receive personal information relating to you in a format that can be processed by a device and the right to have personal information relating to you transferred to another party in certain circumstances; and
to stop unauthorized transfers of your personal information to a third party.

You may also have the right to lodge a complaint in relation to Vincent’s processing of your personal information witha local supervisory authority.

Vincent supplemental notice of collection of personal information and privacy policy under the California Privacy Rights Act (CPRA)

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Last Updated: November, 2023

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This Supplemental Notice of Collection of Personal Information and Privacy Policy (the “CPRA Notice”) applies to the collection of personal information from California residents on and afterJanuary 1, 2023. The CPRA Notice supplements our “Privacy Policy” set forth above to provide California residents with information and rights required by the California Privacy Rights Act (the “CPRA”). The Privacy Policy applies only to individuals residing in the State of California who are considered“consumers” under the CPRA and from whom we collect “personal information” as described in the CPRA.

The CPRA Notice describes the types and categories of personal information we collect, the business purposes for which we collect, use and disclose your personal information and your rights in personal information under the CCPA. We do not share your personal information with third party advertisers for cross context behavioral advertising within the meaning of the CPRA. We do not sell your personal information. We may disclose your personal information, but such disclosures are limited to our service providers and contractors, except where disclosure is required by law, court rules, or applicable rules of professional responsibility to a third party or you provide consent for such disclosure.

For purposes of this CPRA Notice, werefer to personal information according to the following definition given inthe CPRA: “personal information” means information that identifies, relates to,describes, is reasonably capable of being associated with, or could reasonablybe linked, directly or indirectly, with a California resident or household.Personal information does not include publicly available information,information that is de-identified or aggregate consumer information, orinformation or rights that are outside the scope of the CPRA. By accessing our Website,using our services or submitting personal information to us, you consent to thecollection, use and disclosure of such information as set forth in this CPRANotice, as it may be updated from time to time.

What categories ofpersonal information do we collect about you?

We may collect personal informationfrom you in the course of our business, including through your use of our Website,by our use of cookies when you contact or request information from us, when youengage our services or as a result of your relationship with one or more of ourstaff and customers. Much of that data comprises business information, but someof that data may inevitably comprise your personal information.

The categories of personal information we may collect and use includes:

Categories	Examples	Retention Period	Sell/Share to Third Parties
A. Identifiers	This information may include name and contact details (including addresses, telephone numbers, email addresses, IP address, titles and other identifying information).	For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law.	No
B. Customer Information under California Civil Code §1798.80(e)	This information comprises any information that identifies, relates to, describes or is capable of being associated with you in our records. Examples include financial, banking and payment-related information, your signature, identification and background information provided by you or collected as part of our business acceptance processes, including identifying numbers, personal information provided to us by or on behalf of our customers or generated by us in the course of providing our services. Some personal information in this category may overlap with other categories	For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law.	No
C. Protected Characteristics under California or federal law.	Such as race, color, national origin, gender, citizenship, ethnicity, disability, sexual orientation, veteran or military status, religion, or marital status collected in the course of providing our services to you.	For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law.	No
D. Commercial Information	Information and records concerning the services we provide to you, including billing information.	For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law.	No
E. Internet and other electronic history	This category comprises electronic information concerning your use of the Website (https://www.withvincent.com) and dependent pages. We may collect logs of emails and internet use, including your use of the Website, technical information, such as information from your visits to our Website or applications or in relation to materials and communications we send to you electronically.	Generally, for approximately as long as one (1) year	No
F. Educational Information	Sign-up and other educational records and related information may be collected in connection with the services we provide to you.	For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law.	No
G. Inferences drawn from information you provide to create a personal profile concerning your consumer preferences, characteristics, predispositions, behavior, and attitudes	We may accumulate the information you provide in the normal course of the services we provide to make inferences concerning your preferences, characteristics, behavior, abilities and aptitudes. This may include information you provide to us for attending meetings and events, including access and dietary requirements. Similarly, we may develop and communicate marketing and other informational materials concerning our services based on information you provide (e.g., requests to subscribe to certain blogs).	For as long as required for the documents upon which this category is collected pursuant to Vincent retention policy or applicable law.	No

In the past twelve (12) months, depending on the individual circumstances, we may have collected the following categories of personal information: [A-F].

We do not collect sensitive personal information for purposes of inferring characteristics.

Our business reasons for collecting and using your personal information

Depending on the individual circumstances, we collect and use personal information collected from you(however collected), including any personal information, for the legitimate business purposes of Vincent as set forth above. See the sections: How We UseYour Personal Information, Subscriptions to newsletters, Meetings, events and seminars, Other services, Marketing, Business re-organization, and Use ofCookies.

What are our categories of sources of personal information

Vincent collects personal informationfrom the following categories of sources:

directly from you;
service providers and contractors providing services on our behalf; and
third parties, including regulatory authorities, courts and tribunals, government agencies, opposing litigants and law enforcement agencies (such as the police).

Who we disclose yourpersonal information to

We do not “sell” your personal information to, or “share” your personal information with third parties within the meanings of those terms under the CPRA.

In some instances, we may retain other companies and individuals to perform functions on our behalf as “service providers” or “contractors” within the meanings of those terms under the CPRA, including, but not limited to, Information Technology and software providers, website analytics providers and web hosting platforms. Such service providers or contractors may be provided with access to your personal information to perform the functions for which they have been retained.

We will not disclose personal information commercially to any “third party” within the meaning of this term under the CPRA except with your prior permission or where required by law, court rules, or applicable rules of professional responsibility. See the section: Transfers of data to third parties.

In the past twelve (12) months, depending on the individual circumstances, we have not disclosed the categories of personal information collected in Categories [A-F] with outside organizations or entities who are not service providers or contractors providing services on our behalf, except where required by law, court rules or applicable rules of professional responsibility, including but not limited to disclosures that may be permitted or required under rules of civil or criminal procedure. In such circumstances, we have disclosed personal information to the following third parties: courts, regulators, law enforcement and opposing parties among others.

Your rights regarding your personal information

Under the California Privacy RightsAct, you have the following rights in personal information held by us:

You have the right to request that Vincent disclose the personal information that it collects and uses about you. You may “request to know”: (i) the categories of personal information that Vincent has collected about you; (ii) the categories of sources from which the personal information is collected; (iii) the business or commercial purpose for collecting your personal information; (iv) whether any categories of personal information were disclosed for a business purpose to third parties and the categories of third parties with whom Vincent discloses your personal information; and (v) the specific pieces of personal information that Vincent has collected about you. Your request may pertain to the personal information collected about you on or after October 1, 2022. If your request covers a time period beyond twelve (12) months from the date of your request, Vincent may deny your request as to that time period where it would be impossible for Vincent to provide you with the information or involve disproportionate effort. Vincent may deny your request to search for certain information under certain circumstances (e.g., where Vincent retains the information solely for legal and compliance purposes).
You have the right under certain circumstances to receive specific pieces of your personal information in a format that is understandable, and to the extent technically feasible, in a structured, commonly used, machine readable format that allows you to transmit the information to another entity.
You have the right to correct inaccurate personal information.
You have the right to request deletion of personal information under certain circumstances. For example, we may not be required to delete personal information if we need to retain the information to complete the transaction for which the personal information was collected, perform on a contract with us, or to comply with a legal obligation. In addition, we may delay deletion with respect to data stored on an archived or backup system, until the archived or backup system relating to that data is restored to an active system or next accessed or used for a commercial purpose.
You have the right not to receive discriminatory or retaliatory treatment for the exercise of any of these rights. We will not discriminate or retaliate against you or refuse to provide you services because you have exercised your rights.

You may submit verifiable requests concerning any of your rights by contacting us by e-mail to: legal@withvincent.com or by mail at the address below. We will use reasonable methods for verifying that the person making a request to know, data portability, request to corrector a request to delete is the individual about whom we have collected personal information.

This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, youmay be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.

We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten (10) business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five [45] calendar days of the request. If we need additional time to respond to your request beyond the forty-five [45] calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five (45) calendar days to respond to your request.

Access by persons with disabilities

Persons with disabilities who need assistance accessing this CCPA Notice may contact us as provided for above, and depending on your individual needs, Vincent will grant reasonable requests to furnish this policy in an alternative format.

Children

We do not knowingly collect PersonalInformation from children under the age of 13. We do not sell any personal information, including the personal information of minors under 16 years ofage.

NOTICE TO Nevada Residents

We do not sell your personal information to third parties, regardless of the state in which you reside. However, we are required to give this 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 legal@withvincent.comwith the subject line “Nevada Do Not Sell Request” and providing us with your name and email address.

Use of Cookies

We may collect data that may include your personal information by sending “cookies” to your browser, which will store them in your device (e.g., computer, phone, etc.) in order to facilitate your browsing.

A cookie is a small chunk of information sent by our web server to the web browser software that you are using to access the Website. A cookie enables our web server to collect information from your web browser software.

We collect user permission for our use of cookies through a clear notice in the form of a website banner that appears when users view the Website, giving users the option to accept the use of cookies. You are also able to opt-out of the use of non-essential cookies,through options made available on the Website banner.

We use the following types of cookies:

Essential cookies, to provide necessary Website functionality for users. Essential cookies may include, for example, cookies that remember your preferences and settings; cookies that remember certain information that you enter through the Website; or cookies that allow the Website to function properly. Essential cookies are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
Analytics cookies, collecting statistics about the use of the Website by users, such as counting visits and traffic sources, which enable us to measure and improve the performance of our Website. These cookies also help us to know which pages are the most and least popular and see how visitors move around the Website and what content they view.

All Vincent servers and computer systems are designed to be protected from outside intrusions. As a result, all data that may be collected about users through the use of cookies should be protected from unauthorized access.

The data collected through cookies placed on your device will not be kept for longer than is necessary to fulfil the purposes mentioned above; in particular, cookies that we place automatically expire in accordance with the timeframes described above.

You can also change your cookie settings on your browser to block the recording of cookies on your hard drive, in order to minimize the amount of data that may be collected about your navigating on the Website. The procedure for blocking cookies may vary ford ifferent software products. Please check your Internet browser software or with your software supplier if you wish to block cookies. However, disabling cookies may result in certain features of the Website not working, so for optimal use of the Website, we recommend that you do not disable cookies on your device.