Privacy

This site is run by Vera Fund LLC, the sponsor of CYBR Aventura, a development of Vera Fund 6 LLC. The two people who read what you send are Nick Polyushkin and Yury Kharitonenkov. This notice covers this site and the enquiries that start on it, not the other sites it links to. Use of the site is also governed by the terms of use. Questions about this notice go to info@vera.fund, and one of them answers.

There are four forms, and each asks only for what it needs. What you type is sent only when you press the form’s send button, and every form asks you to tick a consent that names this notice and the terms.

• Investor access — your investor type, first and last name, email address, country (or, in the United States, your state), which accredited-investor route describes you (a category, never a figure), an indicative ticket band, and a phone number only if you choose to give one. You also tick three statements: that you are not borrowing from a third party to invest, that you agree to this notice and the terms, and — only if you gave a phone number — that we may call or text you about this offering.
• Talk to Nick or Yury — your first and last name, email address and, if you want a call, a phone number, with the same separate tick for calls and texts.
• Ask a question — your first name, email address and the question.
• Email me the materials — an email address, nothing else.

After you send the investor-access form, the confirmation page may ask how you heard about us. The answer is optional, is a choice from a short list, and is recorded only in our first-party event log, and only if you have allowed Analytics.

With what you send, the record holds: the time it arrived; which form you used and which button on the site led you to it; the address of the page you sent it from; the offering mode the site was showing; that you ticked the consent, and the versions of the consent wording, the disclaimer and (on the investor-access form) the eligibility wording you were shown; on the investor-access form, the outcome the site worked out from your answers and showed you — whether the accredited-investor route you chose can qualify for access; whether you agreed to calls and texts — a number given without that tick is kept marked “do not call or text”; and a random submission ID. If you give a phone number without ticking the call-and-text consent, we will not call or text you.

After we have read an enquiry, the record also carries the sponsor’s note of who evaluated it, when, and what was decided — a record the rules for a private placement expect us to keep.

• Every page request. Our host, Vercel, receives what every website receives: your IP address, browser and device type, the page requested, the referring page and the time. Our server code runs there too; the log lines it writes record what each form did — which form, the result of each check, the status — never the values you typed or your IP address.
• Page speed, on every visit. The site sends our server how fast the page loaded and responded — the measurement, its value and rating, the page’s path and whether the screen is phone- or desktop-sized — with no cookie and no identifier. It is not sent from the financials.
• When you press send. Vercel BotID checks that the form is used by a person: its check script, served from this site’s own address, collects signals from your browser and device. The results are logged without your details.
• To limit repeated requests. When a form fetches its one-time security token (the home-page materials form does this when it scrolls into view, before anything is sent), when a form is sent, when analytics events reach our server and when an access link we sent you is opened, our server keeps a keyed hash of your IP address — never the address itself — in its memory, to count recent requests. It counts them over at most a day (a minute for analytics events), is not written to our logs, and is lost when that server instance shuts down.
• Only after you allow Analytics (see Analytics):
  • Yandex Metrica, on the public pages: the pages you view and the page that referred you (a page view is sent without the query string of either address, but the other events Metrica’s script sends, such as goals and outbound-link clicks, carry the full address of the page you are on), how far you scroll, which sections you read, which buttons and outbound links you click and which expandable notes you open, how long the home page’s opening sequence took and whether you skipped it, the choice you made when you allowed Analytics, your device, browser and screen, your IP address and approximate location, and the identifiers in Yandex’s own cookies and storage.
  • Our first-party event log, kept in our host’s logs: on the investor-access pages, the pages you view there and the same reading and click events as above, which step of the form you reached and how long it took, the name — never the content — of a field that needed correcting, where you stopped, which button led you there, and which confirmation you saw; from the home-page materials form, the name of a field that needed correcting and that the form was sent; that you reached the financials, and nothing inside them; and the optional how-did-you-hear answer.
  • With every event, both receive: whether the screen is phone- or desktop-sized, your reduced-motion setting, whether the browser supports WebGL, whether you are in an in-app browser (such as WhatsApp or Instagram), the offering mode the site shows, and a random ID for this browser tab, deleted when the tab closes or you withdraw consent.
• Cookies and browser storage, including your consent choice — listed in the cookie notice.

We will never ask you on this site for a Social Security number, a tax ID, an account number, a document upload or a password. Nor for your date of birth, your income or net worth as a figure, or any passport or licence number. There is no account to create. These fields do not exist on the site, in any environment.

• To answer you.
• To decide, with you, whether and how this offering may be discussed with you — this offering is open to accredited investors only — and to keep the record that decision needs.
• To keep the site and its forms working and secure: to stop bots, spam and repeated submissions, and to fix errors.
• To see which parts of the site people actually read — only after you allow Analytics.
• To meet legal obligations, answer lawful requests, and establish or defend legal claims.

We do not use your information for a purpose unrelated to these without first asking for, and receiving, your consent.

What you send goes to the sponsor’s own customer-records system, so that Nick or Yury can answer it. The site keeps no copy of its own and sends no email: every reply is written by one of them, from info@vera.fund. These providers receive personal information through the site or from us:

Each provider handles data under its own terms and privacy policy, which can differ from ours. Yandex may also use what it receives for its own purposes (see Sale and sharing). “After you allow” means the provider is not contacted until you switch that category on.

Enquiries go to Nick or Yury. We do not pass them to any third-party adviser, broker or introducer.

Apart from the host’s request data and the page-speed measurements above, nothing that measures your visit runs before you choose. If you allow Analytics, Yandex Metrica runs on the public pages to show which parts of the site people actually read, and our first-party event log records the investor-access pages — the pages you view there, your reading and clicks, and the steps of the form — and the steps of the home-page materials form. Metrica never runs on the investor-access pages, the confirmation page or the financials. From the financials the log records only that the page was reached.

Nothing you type into any form reaches Yandex or the event log — not your name, email, jurisdiction, investor type, route, band, phone or question, and not in any disguised form. The event log records only the name of a field that needed correcting, never what was in it, and the optional how-did-you-hear answer.

We do not use session-recording tools. Yandex Metrica’s Webvisor and click maps are switched off in our code. While your browser sends Global Privacy Control, neither Metrica nor the event log runs, even if you switch Analytics on (see Global Privacy Control).

Cookies are small files a site stores in your browser; similar technologies include local and session storage. The cookie notice lists every cookie and storage item this site uses.

• On your first visit, a box in the corner lets you accept all, reject all, or choose by category: Strictly necessary, Functional, Analytics and Marketing. Only Strictly necessary is on by default. Nothing on this site uses Functional or Marketing.
• Change or withdraw your choice at any time from Cookie preferences at the foot of every page. Switching Analytics off deletes the Yandex (_ym) cookies on this site’s address and its parent domain and the _ym items in browser storage, forgets the tab’s random ID, and — if Metrica had loaded — reloads the page so that it stops. Cookies Yandex set on its own domains stay until they expire or you delete them in your browser.
• Your choice is stored in a cookie named vera_cmp_consent for 365 days: the categories you chose, when you chose, the version of the consent notice, and a random ID for that choice. When it expires, or when a new category or purpose needs your choice, we ask again.
• Your choice applies to the browser and device you used.

What loads regardless of your choices. Vercel, our host, on every page; Vercel BotID, when you send a form. The site’s typefaces and the concept film are served from this site’s own address. None of these is used for analytics or advertising, but Vercel receives your IP address and browser data when your browser contacts the site.

Global Privacy Control

If your browser sends a Global Privacy Control signal, we treat it as a request to opt out of the sale and sharing of your personal information and of targeted advertising. While the signal is on, Analytics and Marketing stay off on this site — Yandex Metrica does not load and our event log stores nothing — even if you switch them on or press Accept all, and Cookie preferences shows that the signal is being honoured. When a page opens with the signal on, the consent tool also removes Analytics and Marketing from a choice you made earlier. The signal applies to the browser that sends it.

Do Not Track

We do not respond to Do Not Track signals. We honour Global Privacy Control as described above.

Once you allow Analytics, Yandex can recognise your browser on other websites that use its services, and may collect information about your online activities over time and across those websites under its own policies.

We do not exchange your personal information for money. The site has no advertising pixels or tags, and nothing sits behind the Marketing category in Cookie preferences. What you send through the forms is not sold and is not shared for advertising.

If you allow Analytics, Yandex receives the information listed for Yandex Metrica under Who receives it and may use it for its own purposes under its terms. Some state laws could treat this as a “sale” of personal information or as “sharing” for cross-context behavioural advertising. Analytics is off until you switch it on, and you can opt out at any time with:

• Cookie preferences — switch Analytics off;
• a Global Privacy Control signal from your browser (see Global Privacy Control).

Opt-outs made in the browser apply to that browser and device. We do not knowingly sell or share the personal information of consumers under 16.

An enquiry that does not lead to an investment is kept for twenty-four months and then deleted. An enquiry that does moves into the sponsor’s own investor records. The evaluation record described above is kept for as long as the rules governing the offering require; that period is being set with counsel, and this notice will state it.

Cookies and browser storage last as the cookie notice lists. Our host’s logs and Yandex Metrica’s data are kept under those services’ own retention settings.

Ask us to delete your details sooner, and we will, except what the law requires us to keep.

• In the United States, by Vercel, and on Vercel’s worldwide edge network, which serves pages from near where you are.
• In Russia, by Yandex Metrica (YANDEX LLC), only after you allow Analytics.
• By Bitrix24, on the server of the portal our team uses, which may be outside the United States, including in Russia; it receives what you send through a form.

The laws of these countries differ from U.S. law, including on when government authorities may access data.

Some state privacy laws give residents rights over their personal information, depending on where they live and whether the law applies to a business of our size and type. Where applicable law gives you these rights, you can use them as described below.

Notice at collection (California)

The table lists the categories of personal information we collect, where they come from, why, and who receives them.

We do not collect sensitive personal information as California law defines it: the accredited-investor route is a category you choose, never a figure, an account number or a document.

Your rights

• Know and access: the categories and specific pieces of personal information we hold about you, where it came from, why we use it, the categories we disclosed and to whom.
• Delete: we delete what we hold about you, except what the law lets or requires us to keep.
• Correct: we correct inaccurate information.
• Portability: a copy of your information in a commonly used format.
• Opt out of the sale or sharing of personal information and of targeted advertising (see Sale and sharing).
• Opt out of profiling used for decisions with legal or similarly significant effects, where state law provides it.
• List of third parties: where state law provides it, a list of the specific third parties to which we disclosed your personal information.
• Non-discrimination: we will not deny you anything, or treat you differently, because you used these rights.

How to submit a request

Email info@vera.fund. Say which right you are using and the state you live in. To opt out of the sale or sharing that Analytics may involve, you can also use Cookie preferences or Global Privacy Control; we do not ask you to verify your identity for that.

We verify a request by matching what you give us with what we hold, for example by replying to the email address in our records. A request to delete, or for specific pieces of information, needs a closer match. We use what you give us for verification only for that purpose, and we will not ask for a Social Security number. We confirm receipt within 10 business days and respond within 45 days. If we need more time, we tell you why and may take up to 45 more days.

Authorised agents. An agent can make a request for you with your signed permission. We may ask you to verify your identity directly or to confirm that you gave the agent permission, unless the agent holds a power of attorney under California Probate Code §§4000–4465.

Appeals. If we decline your request, you can appeal by replying to our decision, or by emailing info@vera.fund with “Appeal” in the subject. We will tell you in writing what we did or did not do, and why, within 45 days of receiving your appeal. If we deny the appeal, we will tell you how to submit a complaint to your state attorney general.

California “Shine the Light”. California residents may ask once a year what personal information we disclosed to third parties for their own direct-marketing purposes (Cal. Civ. Code §1798.83). We do not disclose personal information to third parties for their own direct-marketing purposes. To ask, write to info@vera.fund with “Shine the Light” in the subject.

Nevada. Nevada residents may ask us not to sell their covered information (Nev. Rev. Stat. Chapter 603A). We do not sell covered information as Nevada law defines it, but you can send a request to info@vera.fund.

The site is meant for adults. It is not directed to children under 13, and we do not knowingly collect personal information from them. If you believe a child has sent us personal information, write to info@vera.fund and we will delete it.

The forms are designed so that an enquiry carries none of the identifiers breach-notification law is written around. Every page is served over HTTPS, and access to enquiries is limited to those who need it. No method of transmission or storage is completely secure. If a breach affects your personal information, we will notify you as the law requires.

We update this notice when what the site does changes, and change the date at the top. When a change is material, we post a notice on the site when it takes effect. Where the law requires your consent to a new use, we ask for it first. The record of any enquiry keeps the version of the consent wording that was shown when it was sent.

Vera Fund LLC · info@vera.fund. For privacy rights requests, see Your U.S. state privacy rights.