Privacy Policy

Last Updated: January 1, 2025

Introduction

Airbound Ventures, LLC ("Airbound," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website airbound.org or interact with our firm in any capacity, including when you submit pitch materials, inquire about investment opportunities, subscribe to our communications, or attend events that we host or co-host.

Please read this policy carefully before using our website or submitting any personal information to us. If you do not agree with the terms of this Privacy Policy, please refrain from using our website and services.

This Privacy Policy applies to Airbound Ventures, LLC and its affiliated entities. It does not apply to the practices of third parties whose websites or services may be linked to from our website, or to the portfolio companies in which Airbound Ventures has invested.

Information We Collect

Information You Provide Directly

We may collect personal information that you voluntarily provide to us when you:

• Submit a contact form, pitch inquiry, or investment inquiry on our website
• Subscribe to our newsletter, research publications, or mailing list
• Communicate with us by email, telephone, or postal mail
• Attend events we host, co-host, or participate in as speakers or sponsors
• Apply for positions at Airbound Ventures or its portfolio companies
• Participate in research surveys, interviews, or market studies we conduct
• Connect with us through social media or professional networking platforms

This information may include your name, email address, telephone number, postal address, company name, job title, LinkedIn or other professional profile URL, and the content of your communications with us, including pitch materials, financial projections, and business descriptions.

Information Collected Automatically

When you visit our website, we may automatically collect certain information about your device and browsing activity, including:

• IP address and approximate geographic location (city and country level)
• Browser type, version, and language settings
• Operating system and device type
• Pages visited, time spent on each page, and navigation path through the website
• Referring URL (the page you visited before arriving at our website)
• Search terms used to find our website
• Date and time of each visit
• Technical errors encountered during your visit

This information is collected using cookies, web beacons, and similar technologies. For more detailed information about our use of cookies, please see our Cookie Policy.

Information from Third Parties

We may receive information about you from third-party sources, including:

• Professional networking platforms such as LinkedIn
• Background check and reference services (for potential employees or investees)
• Business information providers such as Crunchbase, PitchBook, or similar databases
• Referrals from founders, investors, or other professionals in our network
• Publicly available sources such as news publications, company websites, and regulatory filings

How We Use Your Information

We use the information we collect for the following purposes:

• Investment evaluation: To evaluate pitch materials, business plans, and funding requests submitted to us
• Communication: To respond to your inquiries, pitch submissions, and requests for information
• Marketing and communications: To send you newsletters, market updates, firm announcements, and event invitations (with your consent where required by applicable law)
• Website improvement: To understand how visitors use our website and to improve its functionality and content
• Due diligence: To conduct background checks and verify information provided in connection with investment opportunities
• Relationship management: To maintain and manage our relationships with founders, investors, advisors, and other industry participants
• Legal compliance: To comply with applicable laws, regulations, legal processes, and enforceable governmental requests
• Business protection: To detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities
• Event management: To organize and manage events, including registration, attendance records, and follow-up communications
• Employment: To process employment applications and manage recruitment activities

We do not sell, rent, or trade your personal information to third parties for their marketing purposes. We do not use your personal information for automated decision-making in ways that produce legal or similarly significant effects without human review.

Legal Basis for Processing (Applicable to EEA Residents)

If you are located in the European Economic Area (EEA), our legal basis for processing your personal information varies depending on the context:

• Contractual necessity: Processing necessary to respond to your inquiries or evaluate your investment application
• Legitimate interests: Processing necessary for our legitimate interests, including website analytics, fraud prevention, and investment deal flow management, where those interests are not overridden by your rights
• Consent: Processing based on your explicit consent, including for marketing communications
• Legal obligation: Processing necessary to comply with a legal obligation to which we are subject

Information Sharing and Disclosure

We may share your information in the following circumstances:

• Service providers: We may share information with third-party service providers who assist us in operating our website and conducting our business, including email service providers, analytics tools, CRM systems, and IT service providers. These providers are contractually bound to use your information only as directed by us and to maintain appropriate security measures.
• Professional advisors: We may share information with lawyers, accountants, auditors, and other professional advisors who are bound by professional confidentiality obligations.
• Co-investors and investment partners: In the context of evaluating or executing an investment, we may share relevant information with co-investors, investment banks, or other parties involved in the transaction, subject to appropriate confidentiality obligations.
• Portfolio companies: If you are a job applicant referred to a portfolio company, or if your inquiry relates to a portfolio company, we may share relevant information with the appropriate portfolio company.
• Regulatory authorities: We may disclose information when required by law, court order, or governmental authority, including to satisfy anti-money laundering (AML), know-your-customer (KYC), and other regulatory obligations.
• Business transactions: In connection with any merger, acquisition, restructuring, or sale of all or a portion of Airbound Ventures' business or assets, your information may be transferred to the acquiring entity, subject to appropriate confidentiality protections.
• With your consent: We may share your information in other ways with your explicit consent.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. For detailed information about the specific cookies we use, their purpose, duration, and your options for controlling them, please see our Cookie Policy.

You can control cookie preferences through your browser settings or by using the cookie consent mechanism on our website. Note that declining certain cookies may affect the functionality and performance of our website.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, and to protect our legitimate business interests. Our general retention guidelines are as follows:

• Contact and inquiry data: Retained for 3 years from the date of last contact, unless a business relationship has developed
• Pitch and investment materials: Retained for 5 years from the date of submission
• Newsletter subscribers: Retained until you unsubscribe or request deletion
• Employment applicants: Retained for 2 years following the conclusion of the hiring process
• Website analytics data: Retained for 26 months
• Event records: Retained for 3 years

You may request deletion of your personal information at any time, subject to our legal retention obligations and our legitimate interest in maintaining records of our business activities.

Your Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information, subject to applicable legal retention requirements
• Objection: Object to certain processing activities, including direct marketing
• Restriction: Request restriction of processing in certain circumstances
• Portability: Request a machine-readable copy of personal information that you have provided to us
• Withdrawal of consent: Where processing is based on consent, withdraw consent at any time without affecting the lawfulness of prior processing
• Complaint: Lodge a complaint with a data protection supervisory authority

To exercise any of these rights, please contact us at privacy@airbound.org. We will respond within 30 days of receiving your request. In some circumstances, we may be unable to fulfill your request — for example, if doing so would conflict with our legal obligations or would adversely affect the rights of others. In such cases, we will explain the reason for our decision.

Massachusetts Residents

Airbound Ventures is headquartered in Boston, Massachusetts. We comply with all applicable Massachusetts privacy and data security laws, including requirements under 201 CMR 17.00 (Standards for the Protection of Personal Information of Residents of the Commonwealth of Massachusetts). We maintain a comprehensive Written Information Security Program (WISP) designed to protect personal information from unauthorized access, use, modification, or disclosure. Our WISP includes administrative, technical, and physical safeguards appropriate to the size and scope of our business and the nature of the personal information we hold.

Massachusetts residents have the right to know what categories of personal information we collect about them and to request access to or deletion of that information. To exercise these rights, please contact us at privacy@airbound.org.

California Residents

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights include the right to know what personal information we collect, the right to delete personal information, the right to correct inaccurate personal information, and the right to opt out of the sale or sharing of personal information.

Airbound Ventures does not sell personal information as defined under the CCPA/CPRA. We do not share personal information for cross-context behavioral advertising. California residents may submit requests to exercise their privacy rights by contacting us at privacy@airbound.org.

Data Security

We implement industry-standard technical, administrative, and physical security measures to protect your personal information from unauthorized access, use, modification, or disclosure. Our security measures include:

• Encryption of data in transit using TLS/SSL protocols
• Encryption of sensitive data at rest
• Access controls limiting personal information access to authorized personnel on a need-to-know basis
• Regular security assessments and penetration testing
• Employee training on data privacy and security practices
• Incident response procedures for addressing potential data breaches

However, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security of information transmitted to or stored on our systems. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately at privacy@airbound.org.

In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and applicable regulatory authorities as required by applicable law.

International Data Transfers

Airbound Ventures is based in the United States. If you access our website or provide information to us from outside the United States, your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. By using our website and providing information to us, you acknowledge this transfer.

For individuals in the European Economic Area, the United Kingdom, or Switzerland, we ensure that any transfer of personal information to third countries is subject to appropriate safeguards, such as standard contractual clauses approved by the European Commission.

Children's Privacy

Our website is not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal information from a child under 16 without verifiable parental consent, we will take steps to delete that information. If you believe we have mistakenly collected information from a child, please contact us at privacy@airbound.org.

Third-Party Links

Our website may contain links to third-party websites, including portfolio company websites, news publications, and professional resources. We are not responsible for the privacy practices or content of those websites and encourage you to review their privacy policies before submitting any personal information. The inclusion of a link on our website does not imply our endorsement of the linked website.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in applicable law, our business practices, or the technologies we use. We will post the revised policy on this page with an updated "Last Updated" date. If we make material changes, we will provide notice through the website or by other appropriate means. Your continued use of our website after changes are posted constitutes your acceptance of the revised policy.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or have concerns about how we handle your personal information, please contact our Privacy Officer:

Airbound Ventures, LLC
Attn: Privacy Officer
200 State Street, Suite 1400
Boston, MA 02109
Email: privacy@airbound.org
Phone: +1 (617) 555-0190

If you are located in the European Economic Area and have concerns about our processing of your personal information that we have not adequately addressed, you have the right to lodge a complaint with the supervisory authority in your country of residence.