Last Modified: March 2024

Introduction

We at Old Well Labs, Inc. (“we,” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this Policy. This Policy describes the types of information we may collect from you or that you may provide to us when you visit the website https://www.oldwell-labs.com/ (our “Website”), and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Policy applies to any information we collect on and in connection with your use of our Website, including any information in any forms or messages submitted by you to us through our Website or using the contact information provided on our Website. This Policy does not apply to any other information that we collect by any other means. Specifically, if your company or organization has subscribed to use our fund manager intelligence software platform and related services, this Policy does not apply to any information collected or processed by us in connection with your or your company’s or organization’s use of such software platform or services; you will need to refer to our contract with your company or organization for information about our policies and practices for collecting and processing information in that context.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you can choose not to use our Website. By accessing or using our Website, you agree to this Policy. This Policy may change from time to time. When we make changes to this Policy, we will post the updated Policy on our Website and update the Policy’s “last modified” date. Your continued use of our Website after we make changes is deemed to be acceptance of those changes.

Information Collected About You and How It Is Collected

We may collect several types of information from and about users of our Website. This may include information by which users may be personally identified or information about a user that is maintained in personally-identifiable form (collectively “Personal Information”). Specifically, we (or our third party service providers acting on our behalf) may collect the following:

• Your (and/or your company’s or organization’s) name.
• Your (and/or your company’s or organization’s) e-mail address.
• Your (and/or your company’s or organization’s) phone number.
• Your (and/or your company’s or organization’s) address.
• The Technical Information described in the section below titled “Traffic, Usage and Computer/Device Information,” such as your IP address or mobile device ID.
• Any other information (including Personal Information) you choose to provide in any forms or messages submitted by you to us through our Website or using the contact information provided on our Website.

With the exception of your Technical Information (which we or our third party service providers collect automatically as you navigate through or interact with our Website, as described below in the section titled “Traffic, Usage and Computer/Device Information”), generally we collect Personal Information directly from you when you provide it or submit it to us directly, such as in connection with registering to obtain additional information from us (such as signing up to receive marketing and promotional information about us or our products and services), contacting us for customer service inquiries, reporting a problem with our Website, submitting an inquiry to us using the contact methods provided on our Website, or otherwise contacting us about our Website or our business.

We may also receive information (including Personal Information) about you or your company or organization from third party service providers we engage. For example, we have engaged Clearbit (https://clearbit.com/) to license certain data and information to us to improve our sales prospecting efforts. For information about Clearbit’s policies and practices for collecting, using and disclosing this information, we encourage you to review their privacy policy at https://clearbit.com/privacy-policy. Additionally, from time to time we may post certain job openings for our business on LinkedIn (https://www.linkedin.com/company/oldwell-labs/jobs/), and if you use LinkedIn to contact us and submit information to us in connection with a listed job opening, LinkedIn will collect certain information about you and share that information with us. For information about LinkedIn’s policies and practices for collecting, using and disclosing this information, we encourage you to review their privacy policy at https://www.linkedin.com/legal/privacy-policy. Please also see the section below titled “Third Party Websites” for more information about interacting with LinkedIn and any other similar third party social media websites.

Traffic, Usage and Computer/Device Information

Additionally, as you navigate through and interact with our Website or interact with the e-mails and other electronic messages we send to you, we or our third party service providers may automatically collect certain traffic data, usage information, and information about your computer equipment or mobile device, such as your browser and operating system, your wireless carrier, the geographic region from which you are accessing our Website, configuration data, clickstream analytics and your actions and patterns when you use our Website (“Technical Information”). The technologies we use for this automatic data collection may include cookies that are stored on the browser of your computer or mobile device, small embedded electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) and other types of embedded code. We collect this information to manage our content and improve users’ use of our Website; to count and review the number of users of our Website and their usage patterns; to track key performance indicators such as pages accessed, frequency of access and other statistical information related to our Website (for example, recording the popularity of certain content and verifying system and server integrity); to identify the portion of users who accesses our Website via different web browsers; to recognize if a user is a return user of our Website; to store information about a user’s visits; to remember a user’s preferences; and for similar purposes in connection with monitoring, operating, maintaining and improving our Website.

How We Use Your Information

Generally

We may use the information we collect about you or that you provide to us, including Personal Information, to:

• Provide our Website and its contents to you.
• Provide you with information you request from us.
• Authenticate or otherwise verify your identity in connection with your requests via our Website or otherwise.
• Provide you with support and to respond to your inquiries and customer service requests, including to investigate and address your concerns and to monitor and improve our responses.
• Update and maintain subscription, e-mail or mailing lists (such as our e-mail lists to receive newsletters or alerts by e-mail).
• Provide you with informational content and promotional materials regarding our Website and our products and services.
• Carry out the advertising, promotional and marketing purposes as described in the section below titled “Use of Personal Information for Marketing Purposes.”
• Help maintain the safety, security, and integrity of our Website, databases and other technology assets and our business.
• With respect to aggregated and de-identified information, fulfill the purposes described in the section below titled “Use and Disclosure of Aggregated or De-Identified Data.”
• With respect to Technical Information, fulfill the purposes described in the section above titled “Traffic, Usage and Computer/Device Information.”
• Notify you about changes to our Website, products or services or this Policy.
• Respond to lawful requests for information through court orders, subpoenas, warrants and other legal processes or obligations.
• Enforce any contracts between you and us, including for billing and collection, or for the establishment, exercise or defense of legal claims.
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information (including Personal Information) held by us is among the assets transferred.
• Fulfill any other purpose for which you provide the information.
• Serve any other purpose that we describe when you provide the information and for any other purpose with your consent.

Use of Personal Information for Marketing Purposes

We may use your Personal Information to provide you with marketing and promotional information about our Website or our products and services or the products and services of affiliates or third parties with whom we have partnered that we believe may be of interest to you. If you do not want us to use your information in this manner, see the section below titled “Choices About How We Use and Disclose Your Information” for more information about how to opt out of such use.

Third-Party Websites

Our Website may include links to blogs, social media and third-party websites. These third-party sites have their own privacy policies and terms of use and are not controlled by this Policy. You should carefully review any terms, conditions and policies of such third-party sites before visiting them or supplying them with any personal information. If you follow a link on our Website to any third-party site, any information you provide to that site will be governed by its own terms of use and privacy policy and not this Policy. You may be able to use social media widgets (e.g., the Facebook “Like” button) while using our Website. These widgets will collect your IP Address and identify which page you are visiting on our Website and make your preference information available to third parties. The information collected by such widgets is controlled by third-party privacy policies.

We are not responsible for the privacy or security of any information you provide to a third-party website or the information practices used by any third-party site, including those that are accessed via links to any third-party site from our Website. We make no representations, express or implied, concerning the accuracy, privacy, safety, security, or the information practices of any third-party site. The inclusion of a link to a third-party site on our Website does not constitute any type of endorsement of the linked site by us. We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third-party website.

Use and Disclosure of Aggregated or De-Identified Data

We may convert or combine some Personal Information of users into de-identified or aggregated data that does not disclose any of the Personal Information of any individual user. As an example, we may de-identify or aggregate information provided by or collected about you and other visitors to our Website to generate aggregate trends or insights about the behavior of visitors to our Website generally that may be shared with third parties. You understand and agree that we may use and disclose to third parties any such de-identified or aggregated data (including traffic and usage data that does not identify you personally) for any lawful purpose.

Tracking and “DO NOT TRACK”

Tracking involves the use of cookies, web beacons, or other embedded code or tracking technologies to collect, analyze and store information on a user’s behavior over time on multiple sites, including information on the sites visited, products viewed, products purchased and other online interactions. Tracking information can be used to enable companies to make interest-based (“behavioral” or “personalized”) advertising available to users on multiple sites that they visit.

We do not currently collect Personal Information about your online activities over time and across third-party sites for tracking purposes when you use our Website. We do not currently allow third parties to collect Personal Information through or using our Website that could be used by them to analyze and store information about your online activities over time and across third-party sites for their own tracking purposes.

Accordingly, our Website does not respond to any “do not track” signals sent by your computer, browser or mobile device, and if your computer, browser or mobile device sends a “do not track” signal to our Website, our Website will not treat you differently from users who do not send such signals. For more information on how to disable certain tracking technologies, please visit the Network Advertising Initiative’s Consumer Opt-Out page at https://thenai.org/opt-out/ and the Digital Advertising Alliance’s Consumer Assistance page at www.youradchoices.com.

Google Analytics

We use Google Analytics to monitor and analyze certain traffic and usage statistics regarding our visitors’ use of our Website, such as the number of visitors to our Website, how visitors are navigating to our Website, visitors’ general geographic region information, how long individuals are visiting our Website, and information about the equipment individuals are using to access our Website, such as browser version and operating system. Google Analytics may use a Google Analytics cookie and may collect your IP address or mobile device ID as part of this service (but neither we nor Google Analytics otherwise collects or processes any of your Personal Information in connection with our use of the Google Analytics services). We use this traffic and usage information to gauge, internally, the effectiveness of our advertising efforts and to make improvements to our Website and our marketing and promotional efforts.

For more information, please review the following:

• Information about Google’s use of cookies: https://policies.google.com/technologies/cookies?hl=en-US
• Information about Google’s use of information from sites or apps that use Google’s services: https://policies.google.com/technologies/partner-sites

You can opt out of our use of certain Google Analytics features by updating the “Ads Settings” in your browser or mobile device (www.support.google.com/ads/answer/1660762#mob), by enabling the Google Analytics Opt-out Browser Add-on in your browser (https://tools.google.com/dlpage/gaoptout), or by visiting the Network Advertising Initiative’s Consumer Opt-Out page (www.optout.networkadvertising.org/). Because those opt-out and preference control pages are specific to the individual browser used to visit it, and because those pages are not operated by us, we are unable to perform the opt-outs on your behalf.

Disclosure of Your Information

We do not sell or lease your Personal Information to any third parties, and we only permit use of your Personal Information internally by our own personnel except in the following, limited circumstances:

• We may disclose Personal Information to any contractors, service providers and other third parties who need to know such information (or such contractors, service providers or other third parties may collect Personal Information directly from you on our behalf while you use our Website) to provide services to us that support our hosting, maintenance, operation and promotion of our Website and our business and our permitted uses of Personal Information under this Policy.
• We may disclose Personal Information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, and in connection with any due diligence review with respect to any such proposed transaction.
• We may disclose Personal Information to comply with any court order, law or legal process, including to meet national security and law enforcement requirements and to respond to any government or regulatory request or audit.
• We may disclose Personal Information to enforce or apply any legal agreements between us and you, or if we believe disclosure is necessary or appropriate to protect the rights, property or safety of our customers or others.

We may also disclose your Personal Information for any purpose disclosed when the information is provided, and for any other purpose with your consent.

Choices About How We Use and Disclose Your Information

You have certain choices regarding the Personal Information you provide to us. You can set your browser to refuse all or some browser cookies. If you choose not to accept cookies, you may be unable to access certain parts or pages of our Website, or certain parts, pages or features of our Website may not function properly.

If you do not wish to have your Personal Information used by us to contact you with informational or promotional content or messages, you may send us an e-mail stating your request to privacy@oldwell-labs.com or you can opt-out by simply clicking on the “Unsubscribe” or “Updating your e-mail preferences” link in the most recent e-mail you received from us and follow the prompts that appear. This opt-out does not apply to customer service or support service inquiries or to notifications about changes to our Website or this Policy.

Please also refer to the section above titled “Google Analytics” for more information regarding opting out of certain Google Analytics features used on and in connection with our Website.

Nevada Residents: Personal Information Sales and Opt-Out Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request by contacting us via e-mail at privacy@oldwell-labs.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Accessing and Correcting Your Information

You may send us an e-mail at privacy@oldwell-labs.com to request access to any Personal Information that you have provided to us, or to correct or delete that Personal Information. For security reasons, we may need to request specific information from you to help us confirm your identity before we correct, update or delete any Personal Information you provide us. We will evaluate such requests on a case-by-case basis. In certain cases, we cannot delete your Personal Information. For example, we cannot continue to maintain your account and/or your subscriptions without retaining certain portions of your Personal Information, so a request to delete certain forms of Personal Information may require the deletion of your account and cessation of services to you. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Users Outside of the United States

Our Website is hosted in the United States and is provided from the United States. It is possible that certain information will be stored on servers in multiple other countries on the “cloud” or other similar distributed hosting platforms. If you are accessing our Website from Canada, the European Union, Asia or any other jurisdiction with laws governing personal data collection, use, and disclosure that differ from United States laws, please note that by using our Website and providing your Personal Information to us through our Website you are expressly and knowingly consenting to the transfer of your Personal Information from your home country to the United States and other jurisdictions as indicated above (where laws may differ from the laws of your jurisdiction) and you are expressly and knowingly consenting to our use of such Personal Information in accordance with this Policy.

California “Shine The Light” Disclosure

The California Civil Code permits California residents with whom we have an established business relationship to request that we provide a list of certain categories of Personal Information that we have disclosed to third parties for their direct marketing purposes during the preceding calendar year. To make such a request, please send an e-mail to privacy@oldwell-labs.com or otherwise contact us using the information set forth below. Please mention that you are making a “California Shine the Light” inquiry. Please note, however, that we do not currently disclose any Personal Information to third parties for their direct marketing purposes.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age, and no one under age 16 may provide any information to this Website. We do not knowingly collect Personal Information from children under age 16. If you are under 16 years of age, do not use or provide any information on this Website, make any purchases through this Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 16 years of age without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under age 16, please contact us at privacy@oldwell-labs.com.

Data Security

We have implemented certain measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.

The safety and security of your information also depends on you. If we have given you (or if you have chosen) a password for access to certain parts of our Website, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information over the Internet is not completely secure. Although we have implemented security measures that we think are adequate, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Website.

Changes to Our Privacy Policy

We post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice on our Website home page. The date the Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Policy to check for any changes.

Contact Information

We are Old Well Labs, Inc., a Delaware corporation. To ask questions or comment about this Policy or our privacy practices, you may e-mail us at privacy@oldwell-labs.com.