Privacy notice

Privacy

This site asks for very little, and only when you choose to write. This page lists all of it: what you give us, what is recorded with it, what we never ask for, who reads it, and how long it is kept.

StatusDraft — pending review by Vera Fund counsel. It describes what this site actually does today. Where counsel changes it, this page changes with it.

Who we are

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. Questions about this notice go to info@vera.fund, and one of them answers.

What you give us — only when you write

Nothing is collected until you use one of the four forms, and each asks only for what it needs:

  • Investor access — your investor type, first and last name, email address, country and 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 name, email address and, if you want a call, a phone number.
  • Ask a question — your first name, email address and the question.
  • Email me the materials — an email address, nothing else.

What is recorded with it

The time you sent it; the version of the consent wording and of the disclaimer you were shown; which button you pressed; your browser’s user-agent string; and the results of our spam checks. 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.

What we never ask for

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.

Why we use it

To answer you. To decide, with you, whether and how this offering may be discussed with you — a private placement may only be made to accredited investors. And to keep the record that decision needs.

Where it is kept, and who sees it

In 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. The site runs on a hosting provider that processes requests in order to serve pages. Neither may use your details for its own purposes.

We do not sell your information, and we do not pass it to any third-party adviser, broker or introducer. Enquiries go to Nick or Yury and to no one else.

Analytics — only after you agree

Nothing that measures your visit loads before you choose. If you accept analytics, Yandex Metrica runs on the public pages to show which parts of the site people actually read. It never runs on the investor-access pages, the confirmation page or the financials. On those pages the site keeps its own record that a step was completed, and nothing more.

Nothing you type or select in any form ever reaches an analytics provider — not your name, email, jurisdiction, investor type, route, band, phone or question, and not in any disguised form.

Page-speed measurements go to our own servers with no cookie and no identifier. A Global Privacy Control signal from your browser is honoured as a refusal of marketing, and there is no marketing tracking on this site in any case.

How long we keep it

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.

Ask us to delete your details sooner, and we will.

Your choices

Change your analytics choice at any time from cookie preferences. Ask for a copy of what we hold about you, a correction, or its deletion, by writing to info@vera.fund. If you gave a phone number without ticking its consent, we will not call or text you.

If something goes wrong

The forms are designed so that an enquiry carries none of the identifiers breach-notification law is written around. If a breach affected your details anyway, we would tell you directly.

Changes to this notice

When this notice changes, the consent manager asks again, and the record of any enquiry keeps the version of the wording that was shown when it was sent.