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Every day, FactorE Ventures PBC (including any entities or Personnel (as defined below) representing the company, collectively "Factor E" or "We") will collect, receive, use and store a variety of Personal Data relating to our investors, donors, investees, employees, business partners, suppliers and various other third parties. This includes (i) data we receive directly (for example, when a (potential) investor, service provider or investee completes a form on our website or corresponds with us by mail, phone, email or otherwise) and (ii) data we receive from other sources (for example, location data; information from business partners and various other sources). It is important that this information is handled in line with the requirements of this policy and Applicable Laws (as defined below). We take our data protection duties seriously and we respect the trust that is being placed in us to use Personal Data appropriately and responsibly.
Privacy, data protection, and related laws and regulations which apply to Factor E, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“EU GDPR”), the EU GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018(“UK GDPR”, together with the EU GDPR referred to as “GDPR”), the Data Protection Act Number 24 of 2019 and its enabling Regulations of Kenya and any privacy and data protection related laws in the United States. The Colorado
Privacy Act does not apply to Factor E as neither minimum qualification requirements are met (service 25,000 Colorado residents or derive revenue from Colorado).
This privacy notice provides information regarding the processing of your personal data when visiting the website of Factor E or interacting with Factor E (“Factor E”, “our”, “us” or “we”).
This privacy notice explains what personal data is processed, for which purposes, how long we hold the personal data for, how to access and update your personal data, the options you have regarding your personal data and where to go for further information.
Links to third-party sites
This notice does not apply to any third-party applications, integrations, or websites that may link to, or be accessible from, our sites and tools. We are not responsible for any of the content, features, functionality, or privacy practices of such linked third-party applications, integrations, or websites. The data collection and use practices of any linked third-party application, integration, or website will be governed by that third party’s applicable privacy notice, statement, or policy, and its terms of use. We encourage you to read them.
Your personal data is controlled by Factor E, whose registered office is at 2520 Nancy Gray Ave Fort Collins, Colorado 80525 USA. This policy applies to all employees and other personnel contracted by or otherwise working for Factor E (collectively "Personnel" or "you") who Process Personal Data on behalf of Factor E. This includes data for which Factor E is a Controller, as well as any customer data that Factor E Processes on behalf of its customers.
Factor E's CFO is responsible for developing and maintaining this policy and any other documents referred to in it, which support this policy (the "Data Protection Framework"). Factor E's Chief Financial Officer ("CFO") is responsible for providing advice, guidance and training on data protection and privacy along with governance and monitoring of, and reporting about data protection and privacy within Factor[e]. The CFO shall also provide advice and guidance to facilitate compliance with this policy throughout any change management process.
Any questions about this policy or any concerns that the policy has not been followed should be referred to the CFO by sending an email to jamie@factore.com .
All Personnel are directly responsible for (i) adhering to this policy, (ii) complying with the data protection guidance of the CFO, (iii) implementing the procedures appropriate to their core business functions and operational area, and (iv) ensuring that their team members comply with this policy, and appropriate guidance and procedures.
Data you provide about yourself
We collect your personal data when you voluntarily provide it to us. For example, you may give us: your email address, country of residence, and areas of interest if you choose to receive newsletters, updates, or other information from us; your contact information, and any other personal data you choose to include, if you email, text, or instant message us, or contact us through our sites and tools; and any personal data contained in, or included with, any proposal documents, social media posts, articles, feedback, comments, responses, messages, chats, photos, videos, or other data or content you submit via our sites and tools. Please do not disclose more personal data than is necessary.
It is always your choice whether to provide this personal data. However, some personal data must be provided to enable certain functions of our sites and tools or enable you to participate in certain programs, activities, or events (such as to sign up for a newsletter, applying for a job, or registering to participate in one of our events), so the decision not to provide such personal data might limit or eliminate such functions or your ability to participate in these programs, activities, or events.
Personal data you provide about others
Do not provide personal data about others unless you are authorized or required to do so by contract or applicable law. You may provide personal data on behalf of another person if you have provided them with a copy of this notice and any applicable supplemental privacy notice, and obtained their explicit or express consent. We may ask you to provide evidence of that notice and consent.
Data we receive from third parties and other sources
We may receive personal data about you from other sources, including your company/organization, professional references, publicly available sources, third-party analytics providers, our service providers, and other third parties. For example, we may receive your personal data if: another person designates you as a contact person for your company/organization or includes information about you in proposal documents, social media posts, articles, feedback, comments, responses, messages, chats, photos, videos, or other data or content submitted through our sites and tools; or one of our employees or service providers or a third party acting on apparent authority provides it to us (for example, when registering you to access one of our sites and tools, access our facilities, apply for a job, or participate in one of our activities or events).
Sensitive personal data
We will not intentionally collect any sensitive personal data (or equivalent concept under applicable law) without your explicit or express consent for one or more specified purposes unless otherwise permitted or required by applicable law.
Interest-based advertising
We may engage third parties to place our interest-based advertisements across the internet for the purpose of engaging and informing you about our organization, activities we fund, and the issues we care about. These third parties may use tracking technologies to collect information about your visits to our sites and tools and other websites and your interaction with our advertising and other communications. Some advertisements may be personalized, meaning that they are intended to be relevant to you based on information collected about your visits to our sites and tools and elsewhere over time.
You may opt out of our collection and use of this information at any time and, in some jurisdictions, we will only engage in interest-based advertising if you have opted in. If you would like more information about this practice and to know your choices concerning interest-based advertisements, please contact us or visit:
United States: http://www.networkadvertising.org/choices/
United States: www.aboutads.info/choices
Canada: http://youradchoices.ca/choices/
EU/EEA: http://www.youronlinechoices.eu/
Minors
Our sites and tools are not intended for minors (individuals under the age of 13, or equivalent minimum age depending on jurisdiction), and we do not knowingly collect personal data from minors through our sites and tools. If you become aware of any personal data we have collected from a minor through our sites and tools, please contact us. If we learn that we have collected personal data from a minor through our sites and tools, we will take steps to delete the data without notice as soon as possible.
Subscribing to our newsletter
We collect personal data about you when you subscribe to our newsletter, such as your e-mail address, your position, and the name of your organization. This is on the basis that you have provided your consent to receive such newsletters.
Generally, newsletters, updates, and other bulk or auto-generated emails from us will include a link to unsubscribe or manage your subscription preferences directly. If you do not wish to receive such promotional communications from us, you can opt-out at any time by following the instructions contained in the communications themselves. If you opt out of receiving these promotional communications, please note that we reserve the right to send you certain communications relating to our sites and tools, including administrative messages. Unless otherwise required by applicable laws, we do not offer you the opportunity to opt out of receiving those communications.
Visiting our website
We collect personal data about you from a variety of sources including from:
The types of personal data includes IP addresses and tracking engagement via data collected from cookies and other similar technologies. Cookies are text files created by websites that transfer information to your computer. Cookies allow websites to remember information about a user, such as a user’s preferences when visiting the Website. As with most websites, Factor E, by itself and through third-party services such as Google Analytics, uses cookies to evaluate use of the Website and improve services. You can generally opt to disable cookies in your browser. However, if you disable cookies, you may not be able to access certain parts of the Website, or certain aspects of the Website may not work correctly.
The purpose for collecting your personal data when you access our website is to ensure the performance of our website. This is because it is in our legitimate interest to ensure our website operates and functions.
We may invite you to attend an event organized or co-organized by us where we collect personal data about you from you. Such personal data will include contact and visitor information and photographs and video footage taken at such events.
It is in our legitimate interest to invite you to events we think will be relevant to you as a stakeholder and process such data accordingly.
Engaging in a program, project and/or investment operated by Factor E or in which Factor E participates (our “Activities”)
We collect personal data about you from a variety of sources including from:
Event photography and audio video recordings
We frequently take photos and record audio and/or video in public areas of our events. If so, we may make and store photographs containing your likeness and recordings of your voice and likeness. We may associate your image and the sound of your voice with your name if you are identified during the recording or identify yourself by name.
We may use, edit, copy, exhibit, publish, or distribute photos and audio or video recording for any charitable purpose relating to the event itself or our events in general (for our legitimate interests).
When we invite individuals to take part in our Activities, we will ask for your contact details such as your name, e-mail address, telephone number and other business contact details necessary to assess the eligibility requirements for our Activities such as your role or position, your business achievements, your business status and other personal data in relation to your eligibility for investment.
If you are eligible for investment, we may ask you to provide further personal data necessary for the performance of the Anti-Bribery and Corruption/Anti-Money laundering and Trade Controls screening, like affiliation with governmental agencies or bodies as well as other information necessary for the performance of the investment agreement, such as the banking details.
We will also collect information that we obtain through your use of the investment from Factor E – such as information about your role, the performance of the Agreement. We will also be provided with information by other entities that are partners in the projects supported by Factor E that may relate to your role and participation in such projects run by the third party– such as due diligence information (e.g. names of key management), banking details and contact details.
The purposes for collecting such personal data include the following:
We may collect personal data about you from sources such as from you, the information we generate about you during our relationship with you and/or third parties as listed above.
We may collect your personal data for the organization and management of Factor E, including financial management, implementation of controls, reporting, analysis, internal audits and investigations. This also includes exercising our legal rights where it is necessary to do so. For example, for the defence of legal claims, to detect, prevent and respond to fraudulent activity.
It is in our legitimate interest to operate Factor E in a safe and lawful way and protect it from legal claims, fraudulent or other unlawful activity.
We may collect personal data from you about if you are applying or interviewing for a role with us or information that is necessary for business travel arrangements, such as visa requirements if you are a contractor.
This is on the basis of it being our legitimate interest to process your enquiry/application for a recruitment opportunity and organizing business travel.
We may commission research. However, we would not collect personal data and any surveys would be anonymized.
There may be circumstances where we need your consent to process your data. If we do, we will ask you for it. In those cases where processing is based on consent, and subject to applicable local law which provides otherwise, you have the right to withdraw your consent at any time. This will not affect the validity of the processing prior to the withdrawal of consent.
Where you choose not to provide us with information set out above for the purposes related to the performance of assessment with regard to our investments or with regard to the performance of our Investment Agreements, this may prevent your ability to be eligible for a role in the deal subject to the Investment Agreement.
If you choose not to provide us with your data in the context of the Factor E newsletter, the only consequence is that it will affect your ability to receive our newsletter.
Purposes
Generally, we may use your personal data to:
Additional purposes
Additional purposes for using your personal data are, or will be, described in a supplemental privacy notice applicable to our engagement with you.
Legal bases under applicable law
We may collect and use your personal data only if we have one or more legal bases for doing so under applicable law. The legal basis or bases will depend on your relationship to us and/or your interaction with our sites and tools. Examples of legal bases on which we rely include where processing is necessary to:
If the legal basis is consent, we will notify you in clear and plain language. We will seek additional consent before using your personal data for a new purpose that is inconsistent with the purpose for which it was collected. Your consent is voluntary and may be withdrawn at any time.
Data Minimization
Factor E will limit its Processing of Personal Data to the minimum amount of Personal Data necessary to pursue its established purposes. When possible, Factor E should use information that does not identify Data Subjects. Factor E will minimize the extent to which it Processes, accesses, or retains Personal Data to the amount necessary for its established purpose. Access to Personal Data should be limited to a need-to-know basis. Absent exceptions, Factor E will not make Personal Data publicly accessible.
Integrity and Quality of Personal Data
Factor[e] endeavors to maintain at all times the integrity of any Personal Data and take reasonable steps to keep Personal Data accurate. Factor[e] will check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.
The personal data covered by this Privacy Notice is exclusively processed for the purposes referred to above and will only be shared on a strict need-to-know basis with:
Where the personal data has been transferred to Factor E and/or to authorized third parties located outside of your country (including outside of the US, UK and European Economic Area) we take organizational, contractual and legal measures to ensure that your personal data is exclusively processed for the purposes mentioned above and that adequate levels of protection have been implemented to safeguard your personal data.
Employees, agents, affiliates, service providers, and partners
We may share your personal data with our: (a) employees, agents, and affiliates who have a business need to know; (b) our services providers (including supplemental staff, project workers, inbound secondees, and outsourced service workers) to process it for us based on our instructions and for no other purpose; and (c) with third-party partners that are collaborating with us to fund or conduct projects or host events. We do not share your personal data with any third party (including our service providers) for marketing purposes unless you have provided consent for us to do so. If you believe personal data you provided to us is being misused by a third party, please contact us right away at info@factore.com.
Other visitors to our sites and tools
Any personal data you include in feedback, comments, responses, messages, chats, photos, videos, or other data or content you submit to interactive portions of our sites and tools (such as comment sections, online forums, and interactive communities) may be viewed by other visitors to those portions of our sites and tools. Other visitors may access, re-post, or use such submissions. In some interactive portions of our sites, you may be able to adjust various privacy settings to control who may see your submission. Even if you remove or delete your submission, copies may remain in cached or archived areas of our sites and tools or be retained by other participants or visitors.
Law enforcement
We may share your personal data with law enforcement, other government agencies or authorities, or third parties, as required by applicable law, court order, subpoena, or legal process, served on us.
Transfer of control
We will not transfer control over personal data to any third party unless such transfer is expressly consented to by you or required to comply with applicable law, court order, subpoena, or legal process served on us.
International Transfer of Personal Data
Where required under Applicable Laws, Factor E will implement appropriate safeguards to transfer Personal Data to jurisdictions different from where Personal Data was collected. If you intend to carry out a Processing activity that involves the transfer of Personal Data, irrespective of whether such transfers occur via third parties or other Factor E entities, you should contact the CFO.
You should be aware, however, that no transmission of data over the Internet is 100% secure, and that unauthorized third parties may unlawfully intercept or access private data. You provide us with this information at your own risk.
Storage and transfers
Your personal data may be stored in your region or in any other country where we or our service providers have facilities. We may also allow employees and service providers worldwide to access personal data as provided in this notice. We will ensure your legal rights and protections travel with any such “transfer” of your personal data as required by applicable law. We do this by signing agreements containing appropriate data protection terms (including “standard contractual clauses,” “standard contracts,” or other terms as may be required by applicable law) and requiring that our employees and service providers protect personal data in accordance with applicable law.
Storage period
We will store your personal data until it is no longer needed to fulfill the purpose(s) for which it was collected or as otherwise required or permitted by law. After such time, we will either delete or anonymize your personal data or if this is not possible, we will securely store your personal data and isolate it from any further use until deletion is possible. We may dispose of any data at our discretion without notice, subject to applicable law. Please contact us at info@factore.com if you would like more details regarding our retention periods for different categories of personal data.
Protection
As the transmission of data via the internet is not completely secure, we cannot guarantee the security of your information transmitted to our sites and tools and any such transmission is at your own risk. However, we maintain appropriate technical and organizational measures, including performing regular self-assessments, to prevent unauthorized disclosure of, or access to, personal data. We limit access to personal data and require that employees authorized to access personal data maintain the confidentiality of that data. Factor E will ensure that only people who are authorized to use the Personal Data can access it and that Personnel who Process Personal Data must have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality. We hold our service providers to at least the same data privacy and security standards to which we hold ourselves.
Factor E will take appropriate security measures to safeguard Personal Data in accordance with our information security policies as determined by IT. These measures will take into account the risks presented by the Processing involved, the nature of the Personal Data concerned, and the cost of implementing such actions. Our information security practices will also include measures to protect Personal Data against unlawful or unauthorized Processing, as well as prevention of the accidental or unlawful destruction, damage, loss, alteration, unauthorized disclosure of or access to Personal Data transmitted, stored or otherwise processed. Factor E will comply with any notification requirements to Supervisory Authorities, other regulatory or governmental bodies or to data subjects, as required under Applicable Laws.
You have certain rights regarding your personal data, subject to local law. We aim to keep our information as accurate as possible. Individuals can access their personal data, request correction or deletion of the personal data and request that the processing of their personal data is restricted. However, there may be situations in which we will not be able to comply with your request for example, due to our regulatory obligations.
If you would like to discuss or exercise any rights you may have, please contact us at info@factore.com. If you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection regulator. In the UK, this is the Information Commissioner’s Office. In the US, this is the Federal Trade Commission.
We have implemented technology and policies with the objective of protecting your privacy from unauthorized access and improper use. In particular, we may use encryption for some of our services, we apply authentication and verification process for access to Factor E services and we regularly test, assess and evaluate the effectiveness of our security measures.
On our website, we may have links to other websites – although such websites have been carefully selected, your personal data collected on those websites will be processed in accordance with the privacy policies and practices of other websites. Please familiarize yourself with these terms.
This Privacy Policy may be changed over time. You are advised to review the Privacy Policy for possible changes regularly. If the changes are significant, we will provide you with an appropriate notice, including e-mail notification if necessary. This Privacy Policy was last updated in February 2025.
This notice describes the different types of cookies and similar technologies we may use in connection with our sites and tools. Unless you have adjusted your browser setting so that it will refuse cookies, cookies may be issued when you visit our sites and tools.
We use strictly necessary cookies to make our sites and tools work. We and our partners also use additional cookies and similar technologies to collect information when you interact with our sites and tools to improve your experience including, to provide you with tailored content, personalized experience, and analyze site usage.
If the site has a “Manage Cookies” button, you can view, change and manage your cookie settings at any time. By clicking “Accept All,” you consent to the placement of these additional cookies and similar technologies. If the site does not have a "Manage Cookies" button, your continued use of the site represents your consent to the relevant cookies and similar technologies being placed on your computer or device. For more information, please see “Managing cookies and similar technologies” section below.
Cookies
Our sites and tools may use cookies, which are small text files stored on your computer or device when you access a website. More information about cookies is available at www.aboutcookies.org. We may use cookies to: (1) allow you to use the sites without having to re-enter your user name and password; (2) understand how you engage with the sites and to enhance or personalize your experience, including across devices; (3) monitor the site usage; (4) manage the sites; and (5) improve the sites and our services, including providing you with interest-based ads. For more information on our advertising, see above: “Interest-based advertising."
We may also use web beacons on our sites and tools, in our emails, and in our advertisements on other websites. Web beacons are tiny graphic images that are used to collect information about your visit to our sites and tools, such as the pages you view and the features you use, as well as information about whether you open and/or act upon one of our emails or advertisements. We may also collect the URL of the website you visited immediately before coming to our sites and tools. Web beacons help us analyze visitors' behavior and measure the effectiveness of our sites and tools and our advertising. We may work with service providers that help us track, collect and analyze this information.
Click-through URLs
If you “opt in” to receive newsletters, updates, or other information from us, our emails may use a “click-through URL” linked to content on our sites and tools. When you click one of these URLs, they pass through a separate web server before arriving at the destination page on our sites and tools. We use this click-through data to help us understand how recipients respond to, or interact with, our emails.
Third-party analytics services
We use third-party analytics services, including Google Analytics and others, to collect information about your use of our sites and tools and enable us to improve our sites and tools. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners. Google Analytics and other third-party analytics services use cookies and similar technologies to collect information about use of our sites and tools and to report trends to us, without identifying individuals to us. We use this information to see the overall patterns of usage on our sites and tools, help us record any difficulties you have with our sites and tools, and tell us whether our communication efforts are effective. We may also link the information provided by third party analytics services with the information we collect, or you provide in other contexts on our site and tools (newsletters, etc.), to personalize, connect and streamline your experience when visiting our sites and tools.
Social media and video sites
If you choose to share our digital content with friends through social networks, such as Facebook and Twitter, or to watch a video posted to a third-party media site (such as YouTube), you may be sent cookies from these third-party websites. We do not control the setting of these cookies, so please check the third-party websites for more information about their cookies and how to manage them.
Cookies
You do not need to have cookies enabled to browse our sites and tools unless you want us to remember you and your preferences when you return. If you prefer not to allow cookies, most cookies can be managed or blocked through your browser. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our sites and tools, or that we may put on our sites and tools in the future. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness. More information about managing cookies is available at the following links:
Click-through URLs
If you prefer not to be tracked in this way, please do not click text or graphic links in emails you receive from us.
Third-party analytics services
You can opt out of data collection or use by Google and other third-party analytics services we may use at the following links:
Do-not-track requests
There is no standard for how online service should respond to “Do Not Track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services. Therefore, we do not honor “Do Not Track” signals. As standards develop, we will revisit this issue and update this notice if our practices change. More information about Do Not Track is available at www.allaboutdnt.org.