PRIVACY POLICY
Last Modified: December 2024
Thank you for visiting https://www.srone.com/ (the “Site”) owned and operated by SR One Capital Management, LP and its affiliated entities (collectively, “SR One,” “we,” or “us”). Please read this Privacy Policy to learn how we treat the Personal Data (defined below) we collect in connection with your use of our Site.
By using or accessing our Site in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of our Site is at all times subject to our Terms & Conditions, which incorporate this Privacy Policy. Any terms that are not defined in this Policy are used as defined in the Terms & Conditions.
As we continually work to improve our Site, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Site, by sending you an email and/or by some other means. Please note that if you have opted not to receive legal notice emails from us (or you have not provided us with your email address), those legal notices will still govern your use of the Site, and you are still responsible for reading and understanding them. If you use the Site after any changes to the Privacy Policy have been posted, you agree to all applicable changes.
Privacy Policy Table of Contents
What this Privacy Policy Covers
How We Disclose Your Personal Data
Exercising Your California Rights
Other State Law Privacy Rights
European Union, United Kingdom, and Swiss Data Subject Rights
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Site, but does not cover the practices of third parties that we do not own, control, or 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 Site. 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.
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations.
This chart details the categories of Personal Data that we collect and have collected over the past 12 months through our Site:
Category of Personal Information (and Examples) | Business or Commercial Purpose(s) for Collection | Categories of Third Parties With Whom We Disclose this Personal Information: |
Profile or Contact Data such as your first name, last name and email address |
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Device/IP Data such as your IP address, IP address-based location, device ID, domain server, MAC address, Type of device/operating system/browser used to access the Site, mobile network information (if applicable) |
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Web Analytics such as web page interactions, referring webpage/source through which you accessed the Site, non-identifiable request IDs, statistics associated with the interaction between device or browser and the Site |
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Other Identifying Information that You Voluntarily Choose to Provide
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In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms, including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, SR One or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
We collect Personal Data about you from the following categories of sources:
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section 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 (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Site and promote our business, provided that we will not disclose such data in a manner that could identify you.
Cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) help operationalize and improve websites. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access a website.
Currently, our Site only utilizes Fathom Analytics, which does not utilize Cookies or similar technologies. This policy will be updated in the event of any changes. The Site does not support “Do Not Track” requests sent from a browser at this time.
Generally, you can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Site and some of the Site and functionalities may not work.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Site, to perform our business or commercial purposes for collecting your Personal Data, or otherwise as may be required by law or regulation. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases, we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
As noted in the Terms & Conditions, our Site is only intended for individuals who are at least 18 years of age and we do not knowingly collect or solicit Personal Data from individuals under the age of 18. If you are under the age of 18, please do not use the Site or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will promptly delete that information. If you believe that a minor under 18 years of age may have provided Personal Data to us, please contact us at privacy@srone.com.
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain Site to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. In addition, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@srone.com.
Access
You have the right to request certain information about our collection and use of your Personal Data. In response, we will provide you with the following information regarding the past 12 months:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. We do not sell your Personal Data.
You may request the above information beyond the 12-month period, but no earlier than January 1, 2022. If you do make such a request, we are required to provide that information unless doing so proves impossible or would involve disproportionate effort.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Site, to complete a transaction or other action you have requested, to comply with applicable law or regulation, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Personal Data Sales and Shares Opt-Out
We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.
Limit the Use of Sensitive Personal Information
Consumers have certain rights over the processing of their Sensitive Personal Information. However, we do not collect Sensitive Personal Information through our Site.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Site as allowed by applicable data privacy laws (including the CCPA) with varying levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
To exercise the rights described in this Privacy Policy, you or your Authorized Agent (defined below) must send us a written request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your name and email address), and (2) describes your request in sufficient detail to allow us to understand, evaluate and provide a response. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request for any rights afforded to you in this Privacy Policy by emailing privacy@srone.com. You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@srone.com.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Site does not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as defined in Nevada Revised Statutes Chapter 603A.
EU and UK Residents
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. SR One will be the controller of your Personal Data processed in connection with the Site.
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@srone.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Examples of these legitimate interests include (as described in more detail above):
Disclosing Personal Data
The “How We Disclose Your Personal Data” section above details how we disclose your Personal Data with third parties.
EU, UK and Swiss Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@srone.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law. In those circumstances, we will still respond to notify you of such a decision. In some cases, you may also need to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Transfers of Personal Data
The Site is hosted and operated in the United States (“U.S.”) through SR One and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Site, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to SR One in the U.S. and will be hosted on U.S. servers, and you authorize SR One to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to standard data protection clauses.
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 do not hesitate to contact us at: