Privacy Policy

Nomic Ventures Management LLC and its affiliated entities (collectively, "Nomic Capital," "we," "us," or "our") are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our websites (nomic.vc and nomic.ventures), use our investment platform, or engage with our services.

Please read this Privacy Policy carefully. By accessing or using our services, you agree to this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access our services.

1.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

• Express interest in investing with us
• Complete subscription documents or investor qualification forms
• Register for our investment platform or services
• Contact us with inquiries or requests
• Subscribe to our newsletters or communications

This personal information may include:

• Identity Information: Full name, date of birth, government-issued identification documents
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account details, investment amounts, accredited investor status, net worth, annual income, employment information
• Tax Information: Social Security Number (SSN), Employer Identification Number (EIN), tax residency status
• Professional Information: Employer, job title, professional background
• Identification Documents: Passport, driver's license, utility bills (for identity verification)

1.2 Identity Verification Information (KYC/AML)

To comply with federal and state securities laws, anti-money laundering (AML) regulations, and Know Your Customer (KYC) requirements, we use Sumsub, a third-party identity verification service provider.

When you complete identity verification through Sumsub, the following information is collected:

• Identity Documents: Passport, driver's license, national ID card, or other government-issued identification
• Biometric Data: Facial images captured during live verification (selfie/liveness check)
• Document Images: Photos or scans of your identification documents
• Verification Metadata: Device information, IP address, timestamp, geolocation (approximate)
• Verification Results: Identity verification status, risk assessment scores, fraud indicators

Important: Sumsub processes this information on our behalf as a service provider. Sumsub has its own privacy policy governing how they handle your data during the verification process. You can review Sumsub's Privacy Policy at https://sumsub.com/privacy-notice/.

We receive only the verification results and necessary identity confirmation from Sumsub. We do not directly access or store raw biometric data collected during the Sumsub verification process.

1.3 Automatically Collected Information

When you visit our websites or use our services, we automatically collect certain information, including:

• Device Information: Browser type, operating system, device type, unique device identifiers
• Usage Data: Pages visited, time spent on pages, links clicked, referral URLs
• IP Address and Location: Your IP address and approximate geographic location
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies (see Section 6 below)

1.4 Information from Third Parties

We may receive information about you from third parties, including:

• Identity Verification Services: Verification results and risk assessments from Sumsub and other KYC/AML service providers
• Background Check Providers: Information to comply with regulatory requirements
• Public Records: Information from publicly available sources to verify accredited investor status or comply with securities regulations
• Professional Contacts: Referrals and introductions from other investors, partners, or advisors

We use the information we collect for the following purposes:

2.1 Investment Services and Account Management

• Processing investment subscriptions and managing investor accounts
• Verifying accredited investor status and investor qualifications
• Facilitating capital calls, distributions, and investment transactions
• Providing investor reporting, tax documents (K-1s), and account statements
• Communicating investment opportunities and portfolio updates

2.2 Regulatory Compliance

• Complying with federal and state securities laws and regulations
• Performing Know Your Customer (KYC) and Anti-Money Laundering (AML) checks
• Conducting background checks and sanctions screening
• Maintaining required records for regulatory examinations and audits
• Responding to subpoenas, court orders, or legal process
• Preventing fraud, money laundering, and other illegal activities

2.3 Service Improvement and Operations

• Operating and improving our websites and investment platform
• Analyzing usage patterns and optimizing user experience
• Conducting research and analytics to improve our services
• Troubleshooting technical issues and providing customer support

2.4 Communications

• Responding to your inquiries and requests
• Sending administrative communications about your account
• Providing updates about our services, investment opportunities, and portfolio companies
• Sending newsletters and marketing communications (with your consent)

2.5 Legal and Safety

• Enforcing our terms and conditions and other agreements
• Protecting our legal rights and interests
• Investigating and preventing fraudulent or illegal activity
• Protecting the safety and security of our users and services

We do not sell your personal information. We may share your information in the following circumstances:

3.1 Service Providers and Business Partners

We share information with trusted third-party service providers who perform services on our behalf, including:

• Identity Verification: Sumsub and other KYC/AML verification providers
• Fund Administration: Third-party administrators for accounting, reporting, and tax services
• Legal and Compliance: Law firms, compliance consultants, and audit firms
• Technology Providers: Hosting services, database management, analytics platforms
• Payment Processors: Banking and payment processing services
• Communication Services: Email service providers and customer support platforms

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

3.2 Legal and Regulatory Authorities

We may disclose your information to government authorities, regulators, law enforcement, or other third parties when required or permitted by law, including:

• In response to subpoenas, court orders, or legal process
• To comply with securities regulations, tax laws, or AML/KYC requirements
• When we believe disclosure is necessary to protect our rights or the rights of others
• To investigate fraud, security issues, or other illegal activity
• To comply with national security or law enforcement requests

3.3 SPV Co-Investors and Portfolio Companies

For investors in our Special Purpose Vehicles (SPVs), we may share limited information with:

• Portfolio Companies: Your name and investment amount (as required for cap tables and investor relations)
• Co-Investors: Investor lists shared with other SPV participants (as permitted by SPV agreements)
• Lead Investors: Information shared with lead investors or other key stakeholders in a deal

3.4 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

3.5 With Your Consent

We may share your information for other purposes with your explicit consent or at your direction.

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention periods include:

• Active Investors: Throughout the duration of your investment relationship with us
• Former Investors: For at least 6 years after final distribution (or longer as required by securities regulations)
• Identity Verification Records: For at least 5 years after account closure (as required by AML regulations)
• Tax and Financial Records: For at least 7 years (as required by IRS regulations)
• Legal and Compliance Records: For the duration required by applicable law or regulation
• Prospective Investors: For 2 years after last contact (unless you request earlier deletion)

After the retention period expires, we will securely delete or anonymize your information unless we are legally required to retain it.

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption: Data transmitted to and from our services is encrypted using TLS/SSL protocols
• Access Controls: Strict access controls limit who can access personal information
• Secure Storage: Personal information is stored in secure, access-controlled databases
• Vendor Security: Third-party service providers (including Sumsub) are required to maintain appropriate security measures
• Employee Training: Our team is trained on data privacy and security best practices
• Regular Audits: We conduct periodic security assessments and audits

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

We use cookies and similar tracking technologies to collect information about your browsing activities and improve your experience on our websites.

6.1 Types of Cookies We Use

• Essential Cookies: Required for the website to function properly (e.g., authentication, security)
• Analytics Cookies: Help us understand how visitors use our website (e.g., Google Analytics)
• Functionality Cookies: Remember your preferences and settings
• Performance Cookies: Collect information about website performance and user experience

6.2 Managing Cookies

Most web browsers allow you to manage cookies through their settings. You can typically set your browser to refuse cookies or alert you when cookies are being sent. Note that disabling cookies may affect the functionality of our website.

To learn more about cookies and how to manage them, visit www.allaboutcookies.org.

6.3 Third-Party Analytics

We use third-party analytics services (such as Google Analytics) to analyze website usage. These services may use cookies and similar technologies to collect information about your use of our website. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

Depending on your location, you may have certain rights regarding your personal information:

7.1 Access and Portability

You have the right to request access to the personal information we hold about you and receive a copy in a portable format.

7.2 Correction

You have the right to request correction of inaccurate or incomplete personal information.

7.3 Deletion

You have the right to request deletion of your personal information, subject to certain exceptions (e.g., regulatory record-keeping requirements, ongoing legal obligations).

7.4 Restriction or Objection

You have the right to request that we restrict processing of your personal information or object to certain processing activities.

7.5 Opt-Out of Marketing

You can opt out of receiving marketing communications from us at any time by clicking the "unsubscribe" link in our emails or contacting us directly. Note that you will still receive transactional and administrative communications related to your account.

7.6 California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

• Right to know what personal information we collect, use, and disclose
• Right to request deletion of your personal information
• Right to opt out of the sale of your personal information (note: we do not sell personal information)
• Right to non-discrimination for exercising your privacy rights

To exercise your CCPA rights, please contact us using the information in Section 11.

7.7 European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR), including the rights listed above, plus the right to lodge a complaint with your local data protection authority.

Our services are based in the United States. If you access our services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other countries where our service providers operate.

When we transfer personal information from the EEA, UK, or Switzerland to the United States or other countries, we implement appropriate safeguards, such as Standard Contractual Clauses approved by the European Commission.

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child without parental consent, we will delete that information promptly.

If you believe we have collected information from a child, please contact us immediately.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated Privacy Policy on our website
• Updating the "Last Updated" date at the top of this policy
• Sending you an email notification (for material changes affecting existing investors)

Your continued use of our services after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will respond to your request within 30 days of receipt. For California residents exercising CCPA rights, we will respond within 45 days.

When you complete identity verification through Sumsub, you are interacting with both Nomic Capital and Sumsub. Here's how the data flow works:

12.1 Data Collection and Processing

• Sumsub collects your identification documents, biometric data (facial images), and device information during verification
• Sumsub processes this data to verify your identity and assess fraud risk
• Sumsub provides us with verification results and confirmation of your identity
• We do not receive raw biometric data or original document images from Sumsub

12.2 Your Rights Regarding Sumsub Data

For questions specifically about how Sumsub handles your biometric data and identification documents, or to exercise privacy rights related to that data, you should contact Sumsub directly:

• Sumsub Privacy Policy: https://sumsub.com/privacy-notice/
• Sumsub Contact: privacy@sumsub.com

For questions about why we require identity verification or how we use the verification results, please contact us using the information in Section 11.

12.3 Retention of Verification Data

• Sumsub retains biometric data and documents according to their retention policy and applicable regulations
• We retain verification results and identity confirmation for at least 5 years after account closure (as required by AML regulations)

12.4 Legal Basis for Verification

We collect and process identity verification information based on:

• Legal Obligation: To comply with federal and state securities laws, AML regulations, and KYC requirements
• Contract Performance: To verify your eligibility to invest and process your investment subscription
• Legitimate Interests: To prevent fraud and protect our business and other investors