Privacy Statement
Effective: September 12, 2023
Please read this privacy statement carefully to understand how we treat your personal information and your choices and rights. If you do not agree with the terms and conditions of this privacy statement, you should not access or use the site.
Clade is an investment collaboration platform that provides teams with the tools to coordinate their work and interact with other users.
Clade (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process.
As you use and interact with our websites, products, and services, we process information from and about you in order to provide access to our tools, an enhanced experience, and support. That means that we collect, use, transmit, store, share, and erase your information.
Clade can be used by companies or by individual users:
If you’re using Clade through your company, or with your company email address, your company’s own Clade administrator is responsible for the accounts associated with that company or institution and can: restrict, suspend, or terminate your access to or ability to use the services, access information about you, access or retain information stored with us (including your workspace content and log data about your use of Clade), and restrict your ability to edit, restrict, modify, or delete information associated with your use of our products and services.
Clade processes information we receive directly from you, automatically collected when you use Clade or visit one of our websites, and collected by Clade from third parties. However, please note that this Privacy Statement does not apply to the processing of your information by third-parties through your use of any third-party integrations available via our services. Please visit those third-party websites directly for more information on their privacy and data protection practices.
Information needed to create an account. This includes information that is needed for us to create an account for you and manage your ability to log in and out of Clade:
- Identifiers, such as first and last name and email address
- Your password for Clade
- Information about your investment qualifications and preferences, size of your portfolio, and type of organization you represent, if any
- Information related to a third-party authentication identity provider, such as Google Authenticator
If you upgrade your account to a paid account, we may collect:
- Billing information, such as name, address, and telephone number
- Financial information, such as credit card information collected by our payment processors on our behalf
- Information about your chosen Clade plan
- Information you provide in onboarding, workspaces, diligence, profiles, notes, email messages, files, videos, data rooms, community, search, tasks, meeting scheduling, invitations, interactions with others such as following, collaboration, liking, commenting and requesting, connecting, question and answering, amongst other features and services
- Information uploaded to Clade, such as text, files, attachments, emails, links, audio, and videos
- Information and attachments from email messages you forward to, and share with, @clade.co and other Clade affiliated email addresses
- Profile photo and other information you choose to include to describe yourself and of your teammates
- Video and audio recordings, and transcripts of those recordings, if you use video messaging, question and answering, diligence, profiles, data rooms, and webinars, amongst other features
- Professional or employment information, such as your title or role at your company
- Any other information you choose to provide while using Clade that identifies or can be reasonably associated with you
- Information about your colleagues and 3rd party contacts, if you choose to provide it
You may voluntarily provide us with information such as when you directly interact with our staff, such as our sales, user research, or user operations groups. We may process:
- Your requests, questions, and responses to us via forms, email, direct message, or audio
- Information to verify your identity
- Your date of birth
- Your audio and video, if you participate in a sales call or user research study and do not opt out of call recording, which also involves the collection of biometric information associated with the call recordings
For information related to your use of Clade and our websites, we may also collect the following:
- Metadata and inference information related to your use of Clade, our websites, and third-party integrations to better understand the way you work in Clade. We may log the actions you take as you use Clade, including, but not limited to, the number of Clade workspaces you work in, the number of team members you have, the types and names of other users you interact with, when you perform a task or comment, the features and embedded content you interact with, the types of files you share, and what, if any, third-party integrations you use.
- Internet network activity, cookies, and similar tracking technologies, including data our servers automatically record, such as your web request, IP address, browser type and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences, and other such information.
- Information collected as a result of participation in beta testing
- Information about how you interact with our marketing websites, like www.clade.co, such as where you click, how long you visit a page, your scrolling, mouse hovers, and other data to help us better understand your experience and provide you with the best user experience
- Device information and activity when you use Clade, such as the type of device you are using, device IDs, operating system version, and mobile network information, which may include your mobile phone number.
- Derived device geolocation information, such as approximate geographic location inferred from an IP address
Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may choose to not allow certain cookies via the cookies consent banner or you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site.
Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of Clade. In addition, adjusting the cookie settings on Clade may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on Clade. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers
Sometimes Clade receives your information from third-parties (other individuals, marketing services, third-party integrations), which may include:
- Information processed from third-party integrations you set up with Clade. For example, a third-party integration may give us access to information stored in that third party that we will process to facilitate the integration
- Name, email, and business contact information
- Information about you provided to us from other individuals and/ or users of Clade
Clade uses your information to operate our products and services, communicate with you and others users, process transactions when you change Clade plans, for security and fraud prevention, and to comply with the law. We may process your information to:
- Provide services and features to you and other users, and operate our business
- Facilitate the exchange of information between you and other users on Clade with whom you may wish to communicate or who may wish to communicate with you
- Facilitate the exchange of information between you and other users on Clade with whom you may wish to learn more about, or who may wish to learn more about you, or whom we believe may benefit from learning more about you
- To verify your eligibility to use the Clade as a fundraiser, investor, or service provider
- Introduce you to other Clade users
- Maintain, provide, and improve our products and services, including training and enhancing our algorithms, improving our machine learning models and databases, and developing new features
- To inform you and other users about opportunities, events, potential investments, or services in which you or them may be interested, including those offered by other users on Clade and as well as other 3rd parties
- Help us better understand user interests and needs, and personalize user experiences
- Analyze and research how you interact with our websites and applications
- Protect Clade and you, for example: securing our systems and products against fraud or unauthorized activity
- Identifying, troubleshooting, and fixing bugs and errors
- Complying with global laws and regulations
- Investigate (in good faith) alleged violations of our Terms of Service
- Comply with a valid legal subpoena, request, or other lawful process or that we otherwise determine is necessary to respond to
- If you use Clade as part of an organization or company, we will process your personal information as required by our contract with your organization. Those contractual terms may differ from, and take precedence over, the uses described in this Privacy Statement.
In addition, we use information about your use of Clade, account information (such as your email address and name), and information related to third-party integrations:
To communicate with you
- About Clade by phone, text, email, or chat
- To share important notices and updates, product changes, and other necessary notices such as security and fraud alerts
- To advertise or market our services and the services of others to you. You have the ability to unsubscribe from promotional communications at any time
- Facilitate reporting and analyze performance of our platform or features available in Clade
- Provide webinars or public presentations
- Demonstrate Clade or provide you access to a demo Clade instance
- Process your information at your direction
- Provide cross-device management of your account. For example, we may locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of our products and services.
- Respond to your requests for information
Help identify and troubleshoot any issues with your account and answer your questions
- Resolve support requests
- Provide you with reports about usage
- Survey your opinions through surveys, research studies, and questionnaires
Unless otherwise prohibited by law, we may combine the information that we collect through your use of our products and services with information that we receive from other sources, both online and offline, and use that combined information as set out above.
Aggregated and De-identified data
We may aggregate and/or de-identify information related to your use of Clade (such as how many workspaces you created) so that such information can no longer be linked to you or your device. We may use such aggregated and de-identified data for any purpose, including but not limited to for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, investors, fundraisers, sponsors, event promoters, and/or others.
We need to share the information we collect about you to make our products and services run smoothly and to operate our business under the following conditions:
- Service Providers and Sub-processors. We may provide access to or share your information with select third parties that use the information on our behalf to assist in providing Clade’s services, website, and features. These third parties provide a variety of services to us, including without limitation sales, marketing, provision of content and features, advertising, analytics, research, data storage, security, fraud prevention, and other services.
- Advertising and Marketing. We may provide information collected when you visit a Clade website (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads and opportunities when you visit other websites.
- User Introductions, Connections. We may share your information to connect you (and/or your organization) with, or offer connections to, users on Clade. This may be proactive, because other users ask for an introduction or connection, or because you and/or your team ask for an introduction or connection, or because we believe it may benefit you and/ or others on Clade
- Research, Diligence, Following. We may share your information with others on the Clade platform who are interested in learning more about you and/or your organization, or in following you and/or your organization.
- Because you ask us to share. We may disclose your information to third parties when you ask us to do so. This includes when you connect Clade with other tools via our available integration, and when you use our services and features in general.
- Consistent with your settings within our products and services. Please note that the information you submit through and share by using Clade may be viewable by other users in a workspace, profile, dashboard, community, database, team, division, organization, and other 3 parties depending on the specific settings you have selected and if an organization has been created for your domain.
- Affiliates and Subsidiaries. We may share the information we collect within the Clade group of companies to provide Clade’s services to you.
- Business Transfers. If the ownership of all or substantially all of our business changes, or all or some of our assets are sold as part of a bankruptcy or other proceeding, we may transfer your information to the new owner so that the services can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Statement until the acquiring party updates it. If such transfer is subject to additional mandatory restrictions under applicable laws or agreements, Clade will comply with those restrictions.
- Compliance with legal obligations. To comply with a valid legal subpoena, request, or other lawful process. We will notify individuals or customers of that request unless: we are prohibited from doing so by law or court order; or there are exceptional circumstances, such as an emergency involving the risk of bodily injury or death to a person or group of people or potential harm to minors.
- If you’re using Clade in connection with an organization or company domain, your company’s own Clade account administrator can export data associated with the domain they manage if they have a subscription plan that allows them to do so.
- Public Forums. Our public forums, such as webinars, collaboration boards, and community forums, make it possible for you to upload and share comments or feedback publicly with other users. Any information that you submit through such public forums is not confidential, and Clade may use it for any purpose (including in testimonials or other Clade marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Such information can be read, collected and/or used by other users, and it could be used to send you unsolicited messages.
Security
Clade takes technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure, and so we cannot ensure or warrant the security of that information.
Storage
By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. Further, you acknowledge that the United States and other countries may not have the same data collection and protection laws as the country in which you reside, and you consent to the use of your personal information in accordance with this Privacy Statement. We may also transfer information that we collect about you to third party processors across borders from your country or jurisdiction to other countries or jurisdictions around the world.
If you are a European Union or Swiss resident, applicable data protection laws may provide you with certain rights with regards to our processing of your personal data. To the extent established under applicable law, European Union or Swiss residents may have the right:
- To access, review, and update their personal data;
- To restrict our processing of their personal data;
- To request that we provide them a copy of, or access to, their personal data in structured, commonly used and machine-readable format (or that we transfer their personal data to another controller, when technically feasible);
- To withdraw their consent when our processing of their personal data is based on consent (and not another legitimate basis);
- To request that we delete their personal data (subject to certain limitations); and
- To lodge a complaint with the applicable supervisory authority in the EU. Before you do this, we ask that you please contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.
To make any of the above requests, please contact us as set forth at the end of this Privacy Statement. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your personal data, you may be charged a fee to the extent permitted by law.
Data Retention
We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Statement, to make our products and services available to you, or as instructed by you, unless a longer retention period is required or permitted by law.
Use By Children
Clade is not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information, the parent or guardian should contact us as set forth at the end of this Privacy Statement, and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable, legally required or permitted, retention standards).
Your Privacy Rights
Please use the “Contact Us” details provided at the end of this Privacy Statement to exercise your rights and choices under this Privacy Statement. We honor such requests when we are required to do so under applicable law.
Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at [email protected] and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Statement or as required by applicable law. For example, you may not opt out of certain transactional, operational, or service-related emails, such as those reflecting our relationship or transactions with you.
Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Privacy Statement. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Privacy Statement.
California Rights
California law entitles California residents to certain additional protections regarding personal data. For purposes of this section alone, “CCPA Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
We collect the following categories of CCPA Personal Information: identifiers, commercial information, Internet or other electronic network activity information, and geolocation data. We collect, use, and disclose CCPA Personal Information in the ways described above in our Privacy Statement. We do not sell CCPA Personal Information to third parties. California residents have the following rights to the extent granted by applicable law:
- Information regarding your CCPA Personal Information we have collected in the past 12 months (including the categories of CCPA Personal Information we have collected, the categories of sources of such information, and the purposes for which we have collected such information);
- Notice of whether we have disclosed your CCPA Personal Information to third parties in the past 12 months (and if so, what categories of information we have disclosed, and what categories of third parties we have disclosed it to);
- A copy of your CCPA Personal Information collected by us in the past 12 months; and
- That your CCPA Personal Information be deleted.
We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this Privacy Statement. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your personal data, you may be charged a fee to the extent permitted by law.
Nevada Rights
Under Nevada law, certain Nevada consumers may opt out of the sale of information about you. We do not sell your data. However, if you are a Nevada resident you may submit a request to opt out of any potential future sales under Nevada law. Please note, if needed, we may take reasonable steps to verify your identity and the authenticity of the request.
Exercising Your Rights
We will need to verify your identity and may need to verify your relationship with Clade (for example, if you’re an administrator of a team on Clade and you’re making a request on behalf of another individual) for security and to prevent fraud.
We may take additional steps to verify that you are authorized to make the request. If you are an end user of Clade’s services and not a direct customer of Clade (for example, your company uses Clade and you’re an employee or authorized representative of that company), you should direct requests relating to your information to the administrator of your company’s Clade account. We will redirect you to your administrator or notify the administrator directly.
Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation.
GDPR Compliance Addendum
In accordance with the General Data Protection Regulation (GDPR), we wish to provide the following additional information to our users within the European Union (EU) and European Economic Area (EEA):
Legal Basis for Processing: We process your personal data based on various legal grounds depending on the nature of the data and the purposes for which we process it. These grounds include processing necessary for the performance of a contract with you, for compliance with a legal obligation to which we are subject, for the purposes of our legitimate interests or those of a third party, or on the basis of your consent, which you may withdraw at any time.
Data Subject Rights: You have the right under the GDPR to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing, and the right to data portability. To exercise these rights, please contact us using the contact information provided.
Right to Lodge a Complaint: If you believe that our processing of your personal data infringes on GDPR regulations, you have the right to lodge a complaint with a supervisory authority, particularly in the member state of your habitual residence, place of work, or place of the alleged infringement.
Data Retention Criteria: We retain your personal data only for as long as necessary to fulfill the purposes it was collected for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. Criteria used to determine the retention period include the magnitude and nature of the data and our legal obligations.
Automated Decision-Making: We do not engage in automated decision-making, including profiling, that would have a legal or similarly significant effect on you without human intervention. Should we implement such processes in the future, we will provide you with information about the logic involved, as well as the significance and the envisaged consequences of such processing.
International Data Transfers: Personal data we collect may be processed and stored in the United States or any other country in which we or our affiliates or processors maintain facilities. We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.
By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy statement.
Data Protection Officer (DPO): We have appointed a Data Protection Officer to ensure our continued commitment to privacy and data protection principles. If you have any questions about the processing of your personal data, your rights under GDPR, or any other data protection matters, please contact our DPO.
Changes To Our Privacy Statement
We reserve the right at any time to make changes to this Privacy Statement simply by posting such changes or updates on Clade and without any other notice to you. If we do this, we will indicate at the top of the page the date the Privacy Statement was last updated. Any such changes or updates will be effective immediately upon posting on Clade. Each time you use Clade, the current version of this Privacy Statement will apply. You understand and agree that your continued use of Clade after we have made any such changes constitutes your acceptance of the most current Privacy Statement, as amended. You can always refuse to accept the changes to our Privacy Statement by terminating your use of Clade.
If you have any questions about our Privacy Statement, please contact our DPO by one of the following options: By e-mail: [email protected], by phone: +1 (212) 235-8000, or by mail: 45 Rockefeller Center, 7th Floor, New York, NY 10111.