Privacy Policy

Gaingels Holdings LP, Gaingels Inc, and our affiliates and subsidiaries (collectively, "Gaingels," "we," "us," or "our") welcome you. Our collection and use of information from visitors and members to our websites, Gaingels.com and portal.gaingels.com (the "Websites") is subject to the following privacy policy (the "Privacy Policy"). By accessing or using the Website, and/or submitting an application for membership in the Gaingels Network, you agree that we may use and disclose your information according to the terms of this Privacy Policy. Websites may contain content or links to content or services provided by third parties. This Privacy Policy does not apply to the practices of those third parties.

Collection, Use, and Retention of Personally Identifiable Information (PII)

Gaingels Network

You are welcome to visit our Websites to learn about the Gaingels Network, its mission and community activities. We collect PII (Personally Identifiable Information) via the Websites when it is provided to us. If you apply to join the Gaingels Network, we collect PII information through our Membership Application (the "Application") which is accessible via the gaingels.com website. The PII we collect includes, but is not necessarily limited to: name, nickname, home address, email address, postal address, phone numbers, birthdate, information regarding your qualifications as an investor, optional demographic information, and links you provide to third party websites or any other information you provide to us.

We process this information to evaluate your application to join the Gaingels Network, open your account, respond to your inquiries, enhance our understanding of network members, and provide relevant information on our Websites. Gaingels may accept or reject your application to join the Gaingels Network at its sole discretion.

Upon becoming an Accredited Member, we collect additional PII information, including but not necessarily limited to: tax identification number, banking information, and current investment positions and/or disclosures where needed. You will have access to portfolio holdings, account transactions and balances via our Investor Portal found at https://portal.gaingels.com/ .

Gaingels Employees Have Access to PII Information

All employees of Gaingels have many roles and responsibilities, most have access to PII information they need to provide assistance to you and to perform their jobs. We use the PII we know about you responsibly to: Enhance administrative issues such as completing forms so that you need only sign them OR Perform Wire or ACH transactions that are authorized by you. We maintain strict internal policies against unauthorized disclosure or use of PII and we do not sell any PII you provide.

Cookies; Third-Party Analytics Providers

We may collect information using "cookie" and other similar technologies. Cookies are small packets of data that a website stores on your computer's or mobile device's hard drive (or other storage medium) so that your computer will "remember" information about your use. We use both first and third party session cookies and persistent cookies.

We use Google Analytics and may use more third–party analytics services to evaluate your use of the Website, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Website you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data. By accessing and using the Website, you consent to the processing of data about you by Google Analytics and these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website.

Third Party Advertisers/Remarketers

We may share or receive information about you with/from third parties, including, but not limited to, advertising and remarketing providers, or similar partners, for purposes of personalizing or otherwise understanding how you engage with ads or other content. These third parties may use cookies, pixel tags, or other technologies to collect information in furtherance of such purposes, including to tailor, target (i.e., behavioral, contextual, retargeting, and remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives. For example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. Information that we may receive from these third parties, including through their service providers, may include advertising identifiers, IP addresses, reports, and campaign data.

By accessing and using the Website, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy.

Onward Transfer to Third Parties

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third-party companies but only to the extent needed to enable them to provide such services.

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy. This policy shall be binding upon Gaingels and its legal successors in interest.

Disclosure to Public Authorities

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Accessing Your Information and Your Choices

We provide reasonable opportunities for individuals to access and update PII information that we have in our possession, by emailing us at membership@gaingels.com or logging into our Investor Portal to update your information.

You can choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending service emails about your account or your transactions with us.

You can choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the site, the site may be impaired and certain features may not function at all.

How We Protect Your Information

Gaingels takes very seriously the security and privacy of the personal information that it collects pursuant to this Privacy Policy. Accordingly, we implement reasonable security measures designed to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and to comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share your information (as permitted herein), nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet.

Information about Children

The Websites are not intended for, or designed to attract, children under the age of 13. We do not collect PII information from any person we actually know is an individual under the age of 13.

Notice to California Residents

Gaingels does not disclose personal information with third parties for direct marketing purposes.

California Consumer Privacy Act Notice. Gaingels is not currently subject to the California Consumer Privacy Act. If we become subject to this law in the future, we will update this Privacy Policy accordingly.

Notices to Nevada Residents

We do not transfer PII for monetary consideration. If your home address is in Nevada and you would like to tell us not to sell your information in the future, please email us at privacy@gaingels.com with the subject “Nevada do not sell” in the subject line.

Notice to Residents of Virginia, Colorado, Connecticut, and Utah

Gaingels is not currently subject to the comprehensive privacy laws of Virginia, Colorado, Connecticut, or Utah. If we become subject to these laws in the future, we will update this Privacy Policy accordingly.

Important Notice to All Non-US Residents

As it pertains to data processing and cross-border data transfers, our operations are located in the United States, and all information submitted through the Websites, or given to employees to enter, is stored on servers in the United States. Please be aware if you are visiting our Websites, that your information may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your country of origin so you choose to use the Website at your own risk.

Under certain circumstances we may have to transfer PII, subject to the GDPR or UK GDPR (as defined below) to countries outside of the EEA or UK and to entities located in jurisdictions which are not subject to an adequacy decision of the European Commission or UK Government. We will always ensure that we have a legal basis for such data transfer, and ensure a relevant safeguard method is in place (e.g. standard contractual clauses, including necessary assessments and supplementary measures) or a derogation applies, so that your Personal Information is treated in a manner that is consistent with, and respects the UK, European and other applicable laws and regulations on data protection. If you require further information about international data transfer, please send an email to privacy@gaingels.com with the subject “International Data Transfer”

European Economic Area (“EEA”) and UK Residents

For the purpose of the UK UK Data Protection Act 2018 (the “DPA”), the EU General Data Protection Regulation 2016/679 (the “GDPR”), and the GDPR as it applies in the UK by virtue of the European Union (Withdrawal) Act 2018 (the “UK GDPR”) and other laws globally, we are the “controller” and are responsible for deciding how Personal Information is used, collected, and processed, unless expressly specified otherwise.

Where you have provided your consent and provided your Personal Information, such consent may be withdrawn at any time.

Where your consent is not mandatory, we may process Personal Information on the following lawful bases:

• For the performance duties between you and us or to answer questions or take steps at your request prior to acceptance into the Gaingels member community.
• As necessary in certain legitimate interests (including our business interests), provided such interests are not overridden by your interests or fundamental rights and freedoms.
• As necessary for our compliance with legal obligations to which we are subject (such as tax reporting and accounting processes).
• We do not anticipate routinely processing special categories of personal information. However, we may do so in certain circumstances, for example where:
  • You have included such information in any communications that you send us, in which case we will consider the provision of such information to constitute your express consent for us to process it; or
  • Processing such personal data is strictly necessary in relation to a legal claim.

For EEA and UK Residents Only:
Under EEA and UK Data Protection Law, in Certain Circumstances, You Have the Right To:

• Request access to any Personal Information we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the Personal Information, the recipients, or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making;
• Obtain without undue delay the rectification of any inaccurate Personal Information we hold about you;
• Request that Personal Information held about you is deleted;
• Prevent or restrict processing of your Personal Information; and
• Request transfer of Personal Information directly to a third party where this is technically feasible.

Also, where you believe that we have not complied with its obligation under this Privacy Statement or UK or EEA law, you have the right to make a complaint to a UK or an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

You can exercise any of these rights by contacting through email at privacy@gaingels.com or by using the details under “How to Contact Us” below.

We aim to respond to requests made by you within one (1) month but may extend that period by two (2) further months where necessary

Do Not Track

Gaingels does not respond to "Do Not Track" settings or other related mechanisms at this time.

Links to External Websites

The Website contains links to third-party websites ("External Sites"). Gaingels does not endorse or recommend the External Sites, and has no control over the privacy practices or the content of any External Sites that we may present to you in the course of your membership. You should review the applicable privacy policies and terms of use when visiting External Sites and especially before providing your personal information. Gaingels is not responsible for the services, content, or privacy practices of External Sites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the last updated date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By accessing the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information collected is governed by the Privacy Policy in effect at the time we collect the information. Please refer to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, you can contact us by email at privacy@gaingels.com or by mail at:

Gaingels
Attn: Compliance Department
43 W 23rd Street, 2nd Floor
New York, NY 10010