PRIVACY POLICY

All Stage, Inc. Privacy Policy (this "Privacy Policy")

Last revised and effective as of: January 22, 2025

This Privacy Policy applies to information collected by All Stage, Inc. ("All Stage" "we" or "us" or "our") through your use of the All Stage website at https://allstage.co, https://allstageinvest.com/, any other website where this Privacy Policy is posted, and any subdomains of the foregoing (the "Site") and the services, features, and information available on the Site and/or any mobile applications we may offer (together with the Site, along with associated and successor websites, applications, features, information, and services, or any part thereof, the "Service"). As used herein, "you" and "your" mean a user of the Service, including investment teams, founders, network organizers, and other individuals who use the Service. As used in this Privacy Policy (a) "GDPR" means the General Data Protection Regulation (EU) 2016/679; (b) "UK Data Protection Laws" means the UK GDPR and the UK's Data Protection Act 2018 ("UK DPA 2018"); (c) "UK GDPR" means the UK equivalent of the GDPR, as defined in section 3(10) (and as supplemented by section 205(4)) of the UK DPA 2018; and (d) "European Data Protection Laws" means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable.

As used in this Privacy Policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within All Stage or among our affiliates within the United States or internationally.

This Privacy Policy serves to notify you of the following:

  1. What information about me is collected?
  2. Where and when is information collected (including through the use of cookies and action tags)?
  3. Is information submitted to the Shared Spaces of the Service private?
  4. Does All Stage collect information from children under 13 years of age?
  5. What does All Stage do with the information it collects?
  6. When does All Stage disclose information to third parties?
  7. Does this Privacy Policy apply when I link to other websites or services?
  8. Is the information collected through the Service secure?
  9. Could my information be transferred to other countries?
  10. For how long will my information be kept?
  11. What choices do I have regarding my information?
  12. How will I know if there are any changes to this Privacy Policy?
  13. Who do I contact if I have any privacy questions?

1. WHAT INFORMATION ABOUT ME IS COLLECTED?

In connection with your use of the Service, we may collect information about you. Such information may include, depending on your use of the Service and whether you are a member of an investment team, a founder, or a network organizer: your name, e-mail address, phone number, location, industries, areas of expertise, accreditation, profile picture, social media handles, company, title, introductory video, bio, documents you choose to share through the Service, investor activity (including deals opened, voting, feedback, commitments, and investments), questions and answers you post on the Service, financial commitments to specific companies, pronouns, gender, sexual orientation, race/ethnicity, veteran status, disability status, education level, and any other information that you submit to the Service. Additionally, our Outside Contractor (as defined below) that is responsible for billing and payment processing services (the "Payment Services Provider") may collect your billing and credit card information from you directly. We may also collect demographic information, browser types, unique device identifiers, device types, requested URL, referring URL, browser language, the pages you view, the date and time of your visit, domain names, and statistical data involving the use of the Service. To the extent any such information can be used to identify you or can be tied to you in an identifiable manner, such information amounts to 'personal data' for the purposes of and as defined in the European Data Protection Laws (to the extent applicable).

We may collect from you, or you may make available to us, some special categories of personal data. By agreeing to this Privacy Policy, you explicitly consent to the processing of any such special categories of personal data. "Special categories of personal data" consist of personal data for the purposes of and as defined in the European Data Protection Laws which is to be treated with particular sensitivity, and includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, data concerning health or data concerning a person's sex life or sexual orientation.

2. WHERE AND WHEN IS INFORMATION COLLECTED (INCLUDING THROUGH THE USE OF COOKIES AND ACTION TAGS)?

We will collect information that you submit to us. We may also receive information about you from third parties providing credit and debit card authorization and fraud screening services as part of your use of the Service. In addition, we may obtain your information from third-party network organizers, or if you identify yourself to us by communicating with us including by sending us an e-mail with questions or comments.

A. Registering to Use the Service and in the Course of Using the Service.

You may be required to establish an account in order to take advantage of certain features of the Service. If so, if you wish to establish an account you will be required to provide us with information such as name, e-mail address, and location. Also, we will have access to any information that you choose to share through the Service.

Please be aware that if you choose to access certain portions of the Services using the Google, LinkedIn, or Microsoft login feature, you may be providing us with access to information, attributes, and data in your Google, LinkedIn, or Microsoft public profile. We may store and use such information in accordance with this Privacy Policy. Such information may be stored by us and may be used in connection with providing the Service or to contact you.

B. Cookies and Action Tags.

We may collect information passively using "cookies" and "action tags."

"Cookies" are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Service and other websites. Cookies can be used to personalize your experience on the Service (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Service (such as saving time by not having to reenter your name each time you use the Service), to allow us to statistically monitor how you are using the Service to help us improve our offerings or to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to collect information in order to provide analytics-related services. In the course of providing analytics-related services, such third-party analytics service providers could place or recognize unique cookies on your browser.

Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the "Help" section of the toolbar. However, if you reject cookies, certain features or resources of the Service may not work properly or at all and you may experience some loss of convenience.

You can find more information about the individual first-party cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose and Type of Cookie Duration
prod_theMemberIdUser IdThis functional cookie recognizes you upon returning to the product.100 days
prod_theMemberNameUser NameThis functional cookie allows you to use our site in a way that makes your browsing experience more convenient by auto-navigating you to the section of the product you were previously interacting with.100 days
prod_theUserTypeUser TypeThis functional cookie allows you to use our site in a way that makes your browsing experience more convenient by auto-navigating you to the section of the product you were previously interacting with.100 days
prod_theCustomerIdCustomer IdThis functional cookie allows you to use our site in a way that makes your browsing experience more convenient by auto-navigating you to the section of the product you were previously interacting with.100 days
forceWorkspaceCookieWorkspace IdThis functional cookie stores information about files uploaded into the product.100 days
prod_theUserTypeAndCustomerIdUser Type and Customer IdThis functional cookie stores information about your preferences, and so allow us to customize the view and display of information for you.100 days
prod_fileUploadCookieUploaded File InformationThis functional cookie stores information about your recent activity, and allows the site to customize the view and display of information for you.100 days
showDealStatusCookieDisplay deal status preferenceThis functional cookie stores information about your preferences, and allows the site to customize the view and display of information for you.100 days
recentDealsList of recently viewed dealsThis functional cookie stores information about your preferences, and allows the site to customize the view and display of information for you.100 days
defaultDashboardViewCookieDashboard display preferenceThis functional cookie stores information about your preferences, and allows the site to customize the view and display of information for you.100 days
paymentNotificationCookiePayment notification display preferencesThis functional cookie stores information about your preferences, and allows the site to customize the view and display of information for you.100 days
prod_dealRecommendationEnablementCookieDeal recommendation preferenceThis functional cookie stores information about your preferenes related to features in the product6 hours
hideActivityFeedCookieRecent activity display preferenceThis functional cookie stores information about your preferenes related to features in the product100 days

For the avoidance of doubt, the Service uses third-party service platforms (including to help analyze how users use the Service). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable "third party" cookies, you may be able to turn them off by going to the third party's website.

Here are links to the main third-party platforms we use:

In addition, we would like you to be aware that we use a Payment Services Provider for payment, analytics, and other business services. This Payment Services Provider may collect your information including via cookies and similar technologies, including when you make a payment through the Service or otherwise interact with our Payment Services Provider that handles billing and payment card processing. The information such Payment Services Provider collects may include transactional data and identifying information about devices that connect to its services. The Payment Services Provider uses this information to operate and improve the services it provides to us, including for fraud detection, loss prevention, authentication, and analytics related to the performance of its services. You can learn more about the Payment Services Provider and read its privacy policy at https://stripe.com/privacy.

"Action tags," also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Service, including e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Service and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete. Information collected from some cookies placed on the website may be used to deliver advertisements to All Stage Site visitors when such visitors are visiting other websites, such as Facebook and LinkedIn.

Finally, you should be aware that third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Service. This Privacy Policy does not govern the use of cookies or action tags or the use of your information by such third-party websites or services or providers of third-party analytics services.

C. Log Files.

We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service. This information may be used to analyze trends, to administer the Service, to monitor the use of the Service, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Service and evaluating the Service in general.

D. Shared Spaces.

The Service may feature various community areas and other forums (the "Shared Spaces") where Service users can share information and post questions for others to answer. These Shared Spaces are open to other users and should not be considered private. We cannot prevent information included within a Shared Space from being used in a manner inconsistent with this Privacy Policy, the law, or your personal privacy. We are not responsible for the results of such postings or for the accuracy of any information contained in those postings.

Any information you share in a Shared Space is by design open to other users and is not private. You should think carefully before posting any information in any Shared Space. What you post can be seen, disclosed to or collected by others and may be used by others in ways we cannot regulate or predict. As with any forum on any website, the information you post may also show up in third-party search engines like Google or Bing. If you mistakenly post information in a Shared Space, you can send us an e-mail to request that we remove it by contacting us at [email protected]. You should understand that in some cases, we may not be able to remove your information.

IS INFORMATION SUBMITTED TO THE SHARED SPACES OF THE SERVICE PRIVATE?

No. Any information shared in the Shared Spaces of the Service is available to other users. Such information is not treated as confidential. If you wish to keep any information private or proprietary, do not submit it to the Shared Spaces of the Service. NOTWITHSTANDING THE FOREGOING, WE HAVE NO RESPONSIBILITY OR LIABILITY IF A USER'S INFORMATION OR IDENTITY IS MISUSED OR STOLEN, OR IF A USER SUFFERS HARM AS A RESULT OF VOLUNTARY DISCLOSURES.

DOES ALL STAGE COLLECT INFORMATION FROM CHILDREN UNDER 13 YEARS OF AGE?

We are committed to protecting the privacy of children. The Service is not designed for or directed to children under the age of 13. We do not collect information from any person we actually know is under the age of 13.

WHAT DOES ALL STAGE DO WITH THE INFORMATION IT COLLECTS?

Pursuant to the European Data Protection Laws, legal bases for our processing your information may include (without limitation):

  1. where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
  2. where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Service or otherwise);
  3. where it is necessary for us to comply with a legal obligation to which we are subject; and/or
  4. where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing, improving, or marketing the Service and your interests or fundamental rights and freedoms do not override those legitimate interests.

We use the information collected to provide the Service to you and process your transactions, to help us understand who uses the Service, for internal operations such as operating and improving the Service, to contact you for customer service and billing purposes, and, unless you 'opt out' (to the extent permitted by applicable law), so that we and third parties acting on our behalf can contact you about products and services that may be of interest to you. We may also process your information we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process (including to meet national security or law enforcement requirements), such as to respond to subpoenas or requests from government authorities.

We may use your information to send you a welcoming e-mail that may confirm your user name and password. Unless you 'opt out' (to the extent permitted by applicable law), we and third parties acting on our behalf may subsequently send you electronic newsletters, contact you about the Service, products, services, information and news that may be of interest to you, and provide you with targeted feedback. If you no longer desire to receive these communications, we will provide you with the option to change your preferences in each communication we send to you. You may also inform us by email to: [email protected].

If you identify yourself to us by sending us an e-mail with questions or comments, we may use your information to respond to your questions or comments, and we may file your questions or comments (with your information) for future reference.

We may also use the information collected to send announcements and updates regarding the Service or, if applicable, about your billing account status. You will not be able to unsubscribe from these Service announcements and updates as they contain important information relevant to your use of the Service and are necessary for the performance of our contract with you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Service. We may link some of this information to other information for internal purposes or to improve your experience with the Service. In addition, we may also anonymize your information (so that it can no longer be associated with you), in which case we may use and/or disclose such anonymous information for our lawful business purposes. We use reasonable safeguards designed to minimize the risks associated with the process of anonymizing your information.

WHEN DOES ALL STAGE DISCLOSE INFORMATION TO THIRD PARTIES?

We generally disclose information we gather from or about you to the following types of third parties and as otherwise set forth in this Privacy Policy or as specifically authorized by you.

A. To Other Users of the Service.

As part of the Service, we may make your information that share on the Service (as further described in Sections 2(D) and 3) available to other users of the Service, including investment teams, founders, network organizers, and other individuals who use the Service. These other users may use your information to review and engage with investment opportunities, connect with other users, or share deal-related information. Please note that information disclosed to these other users of the Service may also be subject to the terms of that other user's privacy policy (as applicable) and your information may be further disclosed in accordance with the terms of their privacy policy (as applicable). Please be aware that we are not responsible for the privacy practices of such third parties.

B. Laws and Legal Rights.

We may disclose your information if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, lawful requests by public authorities, including to meet national security or law enforcement requirements, or other valid legal process. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Service or the general public.

C. Third Parties Generally.

We may provide information to third parties, including where such information is combined with similar information of other users of the Service. For example, we might inform third parties regarding the number of unique users who use the Service, the demographic breakdown of our users of the Service, or the products and/or services purchased using the Service and the vendors of such products and services. In addition to the above, when users use our Service, third parties (including without limitation third-party analytics service providers and commercial partners) may directly collect information about our users' online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include providers of analytics products or services (including vendors, analytics services providers, and website tracking services), merchants, affiliates and other actual or potential commercial partners, and other similar parties. Please note in particular that the Service uses Google Analytics, including its data reporting features. Information collected by Google Analytics includes but is not limited to web metrics. For information on how Google Analytics collects and processes data, please see the site "How Google uses data when you use our partners' sites or apps", currently located at https://www.google.com/policies/privacy/partners/. For information on opting out of Google Analytics, we encourage you to visit Google's website, including its list of currently available opt-out options presently located at https://tools.google.com/dlpage/gaoptout.

D. Professional Advisors.

We may provide your information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

E. Outside Contractors.

We may employ independent contractors, vendors and suppliers (collectively, "Outside Contractors") to provide specific services and products related to the Service, such as hosting and maintaining the Service, providing credit card processing and fraud screening, including the Payment Services Provider, and developing applications for the Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Service, including your information. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your information.

F. Sale of Business.

We reserve the right to transfer information to a third party in connection with a sale, merger, general corporate reorganization, or other transfer of all or substantially all of the assets of All Stage or any of its Corporate Affiliates (as defined below), or that portion of All Stage or any of its Corporate Affiliates to which the Service relates, or in connection with a strategic investment by a third party in All Stage, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding.

G. Affiliates.

We may disclose information about you to our Corporate Affiliates. For purposes of this Privacy Policy: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with All Stage, whether by ownership or otherwise; and "control" means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

H. Network Organizers

If your use of the Service is in connection with our relationship with one of our network organizers with whom you are associated or have a preexisting relationship, we may make your information available to such network organizers.

DOES THIS PRIVACY POLICY APPLY WHEN I LINK TO OTHER WEBSITES OR SERVICES?

Our Service may provide you with access to other websites and services. This may include providing you with the ability to automatically post updates on other sites such as LinkedIn, Facebook, and Twitter/X. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Service. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us or on our behalf, including through the Service.

8. IS THE INFORMATION COLLECTED THROUGH THE SERVICE SECURE?

We want your information to remain secure. We strive to provide transmission of your information from your computer or mobile device to our servers through techniques that are consistent with commercially reasonable standards and to employ administrative, physical, and electronic measures designed to protect your information from unauthorized access.

Notwithstanding the above, you should be aware that there is always some risk involved in transmitting information over the Internet. There is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your information, we cannot ensure or warrant the security or privacy of any information you transmit to us, and you do so at your own risk.

9. COULD MY INFORMATION BE TRANSFERRED TO OTHER COUNTRIES?

Information collected on the Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such information. To the extent required by applicable law: whenever we transfer your personal data to third parties (as described in this Privacy Policy) located in an Inadequate Jurisdiction, we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission (accessible at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) or the UK Information Commissioner's Office (accessible at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/), as applicable, which give personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction.

10. FOR HOW LONG WILL MY INFORMATION BE KEPT?

We will only retain your information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law.

To determine the appropriate retention period for information, we consider the amount, nature, and sensitivity of that information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

We may anonymize your information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. If you are a registered user of the Service, we will retain your information for as long as your account with us remains active. Please note that your account may remain active, and we retain your information, even if you do not renew your subscription to our Services. If you would like us to delete your information, please Section 11 below.

11. WHAT CHOICES DO I HAVE REGARDING MY INFORMATION?

We generally use your information as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such information from you. You generally must "opt in" and give us permission to use your information for any other purpose. You may also change your preference and "opt out" of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting [email protected].

Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:

  1. Request access to your information (commonly known as a 'subject access request'). This enables you to receive a copy of the information we hold about you and to check that we are lawfully processing it;
  2. Request correction of the information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  3. Request erasure of your information. This enables you to ask us to delete or remove your information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your information in certain circumstances;
  4. Object to processing of your information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
  5. Request the restriction of processing of your information. This enables you to ask us to suspend the processing of your information, for example, if you want us to establish its accuracy or the reason for processing it;
  6. Request the transfer of your information to another party; and
  7. Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your information, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct or request erasure of your information, object to the processing of your information, or request that we transfer a copy of your information to another party, please contact [email protected].

Such updates, corrections, changes and deletions will have no effect on other information that we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your information stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

Do Not Track.
The term "Do Not Track" refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

12. HOW WILL I KNOW IF THERE ARE ANY CHANGES TO THIS PRIVACY POLICY?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your information without allowing you to "opt in" to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your information, for which your opt-in is not required. We encourage you to check this page periodically for any changes. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Service.

13. WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?

If you have any questions or comments about this Privacy Policy, please contact us at: [email protected].