Privacy Policy

Welcome to subutai.vc (the “Site”). Subutai Capital Partners, LLC and its affiliated investment fund, Subutai Capital Fund I, LP (collectively, “Subutai,” “we,” “our,” or “us”) are committed to respecting and protecting your privacy. Please read this Privacy Policy carefully to learn about how we treat your personal data. By using or accessing our Site in any manner, you acknowledge that you accept the practices and policies outlined below, and you consent that we will collect, use, and disclose your information as described herein.

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. If you use the Site after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

What This Privacy Policy Covers

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 companies we don’t own or control or people we don’t manage, nor 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 our Site.

Investor Privacy: This Privacy Policy applies to information collected through our public-facing Site. We do not collect investor Personal Data through this Site. Limited partner and investor information is collected directly from accredited investors during the subscription process and through confidential offering materials. The collection and processing of investor Personal Data, including information such as name, address, government-issued identification, and information relating to investments, assets, and income, is governed by our fund subscription documents and conducted in accordance with applicable securities laws and regulations. If you are an investor and have questions about how we handle your Personal Data, please contact us at investors@subutai.vc.

“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information,” “personal information,” or “sensitive personal information” under applicable data privacy laws, rules, or regulations.

Personal Data

Categories of Personal Data We Collect

This table details the categories of Personal Data that we collect through our Site and have collected over the past 12 months:

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing, and Improving the Site

• Providing you with the information you request
• Responding to founder pitch deck submissions and investment inquiries
• Evaluating investment opportunities and conducting preliminary due diligence
• Responding to general inquiries about the fund
• Meeting or fulfilling the reason you provided the information to us
• Providing support and assistance for the Site
• Personalizing the Site and content based on your preferences
• Improving our Site and user experience
• Performing fraud protection, security, and debugging
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws

Corresponding with You

• Responding to correspondence that we receive from you
• Contacting you when necessary or requested
• Sending you information about Subutai or our portfolio companies
• Sending emails and other communications according to your preferences
• Sharing industry insights, portfolio company updates, and market intelligence (with your consent)

Marketing and Business Development

• Identifying and attracting potential investment opportunities
• Building relationships with founders and entrepreneurs
• Connecting with qualified potential investors
• Analyzing market trends and investment opportunities

Other Permitted Purposes for Processing Personal Data

In addition to the above, each category of Personal Data may be collected, used, and disclosed for the following purposes:

Legal Compliance and Protection

• Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process
• Preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities
• Protecting the rights, property, or safety of you, Subutai, or another party
• Enforcing any agreements with you
• Responding to claims that any posting or other content violates third-party rights
• 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.

Categories of Sources of Personal Data

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

You

When you provide such information directly to us:

• When you contact us or submit an inquiry form
• When you submit a pitch deck or business plan
• When you request general information about the fund
• When you voluntarily provide information in free-form text boxes through the Site
• When you send us an email or otherwise communicate with us
• When you subscribe to updates or communications

When you use the Site and such information is collected automatically:

• Through Cookies (defined in the "Tracking Tools" section below)
• Through your device and browsing behavior

Third Parties

Vendors and Service Providers:

• Analytics providers to analyze how you interact and engage with the Site
• Third parties who help us provide customer support
• Vendors who help us obtain information to generate leads and create user profiles

Business Partners:

• Co-investors or syndicate partners (for investment-related information only)
• Portfolio companies (when they refer founders or opportunities to us)

Public Sources:

• Publicly available information about companies, founders, or investors

How We Disclose Your Personal Data

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” or “sharing” of your Personal Data under certain definitions. For more information, please refer to the state-specific sections below.

Service Providers

These parties help us operate the Site or perform business functions on our behalf. They include:

• Hosting, technology, and communication providers
• Security and fraud prevention consultants
• Analytics providers (e.g., Zoho Analytics)
• Customer relationship management (CRM) platforms
• Email service providers

Business Partners

These parties partner with us in offering various services or conducting investment activities. They include:

• Co-investors and syndicate partners
• Portfolio companies
• Legal, accounting, and other professional advisors
• Fund affiliates and service providers

Parties You Authorize, Access, or Authenticate

• Third parties you access through the Site
• Other users (when you choose to share information)
• Parties you explicitly consent to us sharing your information with

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under the “Other Permitted Purposes for Processing Personal Data” section above, including:

• Government or law enforcement officials
• Courts and legal proceedings
• Parties to legal claims or disputes

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). You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data.

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 to 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.

Tracking Tools, Advertising, and Opt-Out

The Site uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Site, analyze trends, learn about our user base, and operate and improve the Site. 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 our Site. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Types of Cookies We Use

Essential Cookies

Essential Cookies are required for providing you with features that you have requested. For example, certain Cookies enable you to remember your preferences. Disabling these Cookies may make certain features unavailable.

Functional Cookies

Functional Cookies are used to record your choices and settings regarding our Site, maintain your preferences over time, and recognize you when you return to our Site. These Cookies help us to personalize our content for you and remember your preferences (for example, your choice of language or region).

Performance/Analytical Cookies

Performance/Analytical Cookies allow us to understand how visitors use our Site. They do this by collecting information about the number of visitors to the Site, what pages visitors view on our Site, and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help us measure the performance of our communications and content in order to help us improve our Site.

Zoho Analytics: We use Zoho Analytics to analyze Site usage and visitor behavior. Zoho’s ability to use and disclose information collected about your visits to the Site is subject to Zoho’s Privacy Policy, available at https://www.zoho.com/privacy.html.

Your Cookie Choices

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 functionalities may not work.

To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit www.allaboutcookies.org.

Do Not Track Signals

Please note that because of our use of Cookies, the Site does not support “Do Not Track” requests sent from a browser at this time. Some third-party sites do keep track of your browsing activities. If you are visiting such sites, your browser may allow you to set the DNT signal so that third parties know you do not want to be tracked. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Data Security and Retention

Data Security

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. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication requirements
• Employee training on data protection
• Secure data storage and backup systems

You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism (if applicable), limiting access to your computer or device and browser, and signing off after you have finished accessing any secure areas. 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. We cannot guarantee absolute security.

Data Retention

We retain Personal Data about you for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to perform our business or commercial purposes for collecting your Personal Data. 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
• The sensitivity of the Personal Data
• Legal and regulatory requirements

In some cases, we retain Personal Data for longer if doing so is necessary to comply with our legal obligations, resolve disputes, 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.

Typical Retention Periods

• Founder pitch deck submissions: 5 years or until you request deletion
• General inquiries: 3 years or until you request deletion
• Website analytics and cookies: 26 months
• Email correspondence: Duration of relationship plus 3 years

Personal Data of Children

We do not knowingly collect or solicit Personal Data from children under 18 years of age. Our Site is directed to business professionals, investors, and entrepreneurs. If you are under the age of 18, please do not attempt to 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 delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at privacy@subutai.vc.

Your Rights and Choices

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your California Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our portfolio companies’ employees or users in connection with our provision of certain services. 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.

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@subutai.vc.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you
• The categories of sources from which that Personal Data was collected
• The business or commercial purpose for collecting or selling your Personal Data
• The categories of third parties with whom we have shared your Personal Data
• The specific pieces of Personal Data that we have collected about you

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.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the California Consumer Privacy Act (CCPA), this right is subject to certain exceptions: for example, we may need to retain your Personal Data to complete a transaction or other action you have requested, or to comply with legal obligations. If your deletion request is subject to one of these exceptions, we may deny your deletion request but will explain our reasoning.

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. If your correction request is subject to one of these exceptions, we may deny your request but will explain our reasoning.

Personal Data Sales and Shares Opt-Out

We do not sell or share your Personal Data, and have not done so over the past 12 months. To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age. If our practices change, we will update this Privacy Policy and provide you with an opportunity to opt out.

Limit the Use of Sensitive Personal Information

We do not collect Sensitive Personal Information through this Site. Sensitive Personal Information (such as government-issued identification and financial account information) is collected directly from investors during the subscription process and is not subject to this Privacy Policy.

We Will Not Discriminate Against You for Exercising Your Rights

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you access to our Site, charge you different prices or rates, or provide you a lower quality of service if you exercise your rights under the CCPA.

Exercising Your California Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that:

1. Provides sufficient information (including first name, last name, and/or email address) to allow us to verify that you are the person about whom we have collected Personal Data, and
2. Describes your request in sufficient detail to allow us to understand, evaluate, and respond to it.

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. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt, as required by the CCPA. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly 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 by:

• Emailing us at privacy@subutai.vc
• Mailing us at 732 S 6th St #5489, Las Vegas, NV 89101

Authorized Agents: 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.

Other State Law Privacy Rights

Nevada Residents

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 sales are defined in Nevada Revised Statutes Chapter 603A. If our practices change, we will update this Privacy Policy and provide Nevada residents with appropriate opt-out mechanisms.

Virginia, Colorado, Connecticut, and Utah Residents

If you are a resident of Virginia, Colorado, Connecticut, or Utah, you may have additional rights under your state’s privacy laws, including the right to access, correct, delete, and obtain a copy of your Personal Data, as well as the right to opt out of certain processing activities. To exercise these rights, please contact us using the contact information provided below.

Other States

We will update this Privacy Policy as additional states enact comprehensive privacy legislation. If you reside in a state with privacy laws that provide rights not explicitly addressed here, please contact us, and we will work to honor those rights to the extent required by law.

International Data Transfers

Our Site is operated in the United States. If you are accessing our Site from outside the United States, please be aware that your Personal Data may be transferred to, stored, and processed in the United States where privacy laws may differ from those in your country of residence.

By using the Site, you consent to the transfer of your Personal Data to the United States and other jurisdictions as necessary to operate the Site. We will take appropriate measures to ensure that your Personal Data receives an adequate level of protection in the jurisdictions in which we process it.

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 do not hesitate to contact us:

For investor-specific privacy inquiries, please contact: investors@subutai.vc