Privacy Policy

Introduction

The Hiive Company Limited and its affiliates (“Hiive”, “we”, “us”, or “our”) help individuals and institutions, or their representatives, buy and sell stocks in late-stage, venture-backed companies primarily through our online platforms at hiive.com (the “Platforms”) and associated products and services.

This privacy policy (the “Privacy Policy”) applies to you (“you” or the “user”) if you access or use the Platforms, whether on behalf of yourself or your customer, access our website located at www.hiive.com (the “Website”), have requested or received a demonstration of the Platforms, or subscribed to our publications (collectively, the “Services”). If you are accessing and using the Platform on behalf of your customer at http://connect.hiive.com/, then references to Personal Data about you and your privacy in this Privacy Policy are also references to the Personal Data and privacy of your customers.

In order to deliver these Services effectively, efficiently, securely and in compliance with applicable law, we may collect, use, share, retain and transfer information (collectively, “process") about you (“Personal Data”).

We understand that you care about your privacy, and we take your privacy seriously too. In fact, we think about how to protect your privacy at all points you interact with the Services. In this Privacy Policy, we explain what information we process about you and how we do so. We also let you know what rights you have in respect of controlling or accessing this information.

If you have created an account on one or both of the Platforms, this Privacy Policy is incorporated into the applicable Platform terms and conditions that govern your access to and use of the Services. By accessing the Services, you agree to be bound by the latest published version of this Privacy Policy.

Information we collect, how we use it, and legal bases for processing

Device and usage data

As is true of most other websites, the Website and the Platforms collect certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other information about your use of the Website or the Platforms, including a history of the pages you view.

We use Google Analytics solely to track your browsing session's movement within hiive.com. If you wish to do so, you may opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout/. We also use applications called Amplitude and Pendo which are user analytics providers to give us insight into user engagement of the Website and Platforms to improve the user experience.

The purpose for our processing of device and usage data information is to assist us with fraud prevention and provide and improve the Services by, amongst other methods, diagnosing problems with our server, designing our Website to better suit our users' needs, analyzing user trends, and reviewing broad demographic information to identify visitor preferences.

Cookies and tracking technologies

The Website and the Platforms use cookies and similar technologies to analyze trends, administer our Website and the Platforms, track users' movements around the Website and Platforms, and gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, for example, by using a browser’s “do not track” functionality. However, if you choose to disable cookies, it may limit your use of certain features or functions on the Website or the Platforms. As well, as there is not yet a commonly accepted industry standard for this type of technology, we do not commit to responding to “do not track” signals with respect to our Services. Hiive takes your privacy seriously and will continue to monitor developments in this area.

For both device and usage data as well as cookies and other tracking technologies, Hiive has a legitimate interest in understanding how visitors, customers, and potential customers use the Website and Platforms. This information assists Hiive with providing more relevant products and services and with ensuring appropriate resources to meet customer and Website visitor needs.

Other Personal Data collected through the Hiive Website

If you visit the Website, including to subscribe to our publications, sign up for a demo of the Platforms or apply for a job, Hiive may, as applicable, request additional Personal Data from you, such as your name and contact information, a copy of your resume and other relevant information.

The purpose of processing this information is to respond to your request of, or outreach to, Hiive. Hiive has a legitimate interest in collecting this information to respond to your request of, or outreach to, Hiive which may include, as the case may be, providing you with a subscription to the latest Hiive updates or demo to better understand the Services and meeting Hiive’s staffing needs.

Hiive Platform onboarding

If you or you, on behalf of your customer, want to create an account on and use one or both of the Platforms, we will need to process additional Personal Data. This information may include the following: full name, employment information, mailing address, email address, phone number. Depending on the purpose for which you intend to use the Platforms, we may also ask you questions about your investment plans, the securities that you are interested in buying, selling or adding to your watchlist, your net worth, income or experience in private stock investing, and other questions that will help us determine whether and to what extent you are eligible to use the Platforms. As part of our identity verification processes, we may ask for a copy of, or any information contained on, a piece of government-issued identification such as a driver's license or passport, date of birth, and a “selfie” (i.e. a photograph of yourself) to compare with the photo on your identification.

The purpose and the legitimate interests of Hiive in collecting this information is to provide and improve the Services to you, securely authenticate your access to the Platforms, prevent fraud, update you on relevant activity on the Platforms, and to meet Hiive’s legal obligations under applicable law.

Hiive Platform activity and transactions

If you become a registered user or customer on the Platform, in addition to the information listed under the heading of “Hiive Platform onboarding” above, we may collect additional information, depending on the Platform you will be using and accessing, and how and to what extent you utilize and engage with the functionality of that Platform. This may include information on your bids, shareholdings, vested options, and similar types of securities, documents pertaining to such, whatever information, if any, that you provide in communications with counterparties through Hiive’s messaging functions, and your signature on any execution documents that you or your customers may choose to sign. Hiive’s registered representatives will have access to copies of any of your messaging interactions.

The purpose of Hiive processing such information is to facilitate your transaction, provide feedback on your postings (such as on bid or list prices), and to ensure that transactions and any negotiations on the Platform are bona fide, comply with Hiive’s terms and conditions, and do not breach relevant securities laws.

Hiive has legitimate interests in collecting this information, including to provide the Services, facilitate execution of transactions through the Platforms, ensure that the Platforms are effective, and monitor and track activity on the Platforms in order to meet Hiive’s legal obligations under applicable law.

There are five main purposes for our processing of information on the Platforms related to your onboarding, activity, and transactions on the Platform. They are:

1. to undertake due diligence activities in compliance with applicable law, such as meeting our “know your client” obligations, confirming your and/or your customers’ identities, and running anti money laundering checks;
2. to communicate with you about your use of the Platforms, including to provide support services, send you invoices or assist you with transactions;
3. to facilitate the negotiation and completion of transactions with other users of the Platforms. Generally speaking, your identity is anonymized throughout your interactions on the Platforms; however once you are introduced to a counterparty by Hiive or enter into a messaging interaction with another user or accept a bid, some of your Personal Data (including name and email address) may be shared with the counterparty;
4. to collect data about and track your usage of the Platforms, so that we can better understand usage patterns and improve our services, collect anonymized and aggregated information about pricing and market activity, and meet our legal obligations to monitor for fraud or suspicious activities; and
5. to send you updates about Hiive via email or telephone, including feature announcements, Platform activity notifications and policy updates.

As required by law or regulatory authorities

We will process any Personal Data as required by applicable law, regulatory authorities, or legal process and to comply with our obligations as a broker-dealer.

To manage our relationship with you

We will also process any Personal Data to manage our relationship with you, including notifying you about updates to our terms and conditions and Privacy Policy.

Limited Purpose

Except as required by applicable law or regulation and to comply with our obligations as a broker-dealer, we will process your Personal Data only for the purposes for which you’ve provided it.* For example, if you apply for a job at Hiive, we will use your phone number and email address to contact you to request additional relevant documents or schedule an interview, and your resume to consider whether you are eligible or qualified for the position you applied for. If you request a demo, we will use your Personal Data to target our communications and demonstration to your needs, and to send you relevant documents and communications about using the Platforms or buying or selling private securities.

*This is with the exception of information that is automatically collected as disclosed above (ie. device and usage data, and cookies and tracking technologies).

Who we share Personal Data with

We do not sell Personal Data to anyone and only share it with counterparties, potential counterparties, and other third parties such as issuers and payment agents, as applicable, and as necessary to facilitate your transactions or potential transactions. We also share Personal Data with third parties who are facilitating the delivery of our Services as described below.

From time to time, Hiive receives Personal Data about individuals from third parties. We may collect your Personal Data from a third-party website (e.g. LinkedIn) or request information from your former or current employers if you are applying for a job at Hiive.

We use a number of third parties to power the Website, Platforms, and Services, which means that your Personal Data may be transferred to these service providers as necessary. In all cases we make sure that our service providers only process Personal Data as minimally necessary to provide the functions we have described below. We enter into contracts and undertake diligence to ensure that these service providers provide at least the same level of protections that Hiive provides for your Personal Data. The services providers we use at this time assist us with the following: cloud hosting and performance monitoring, data processing and management infrastructure, usage analytics, content delivery networks, digital contract management and e-signature services, electronic communications archiving and monitoring, instant messaging services, email delivery and management services, communication tools and interaction analytics, document storage and communication management systems, digital calendar management services, customer relationship management systems, automated notification and alert systems, software feature management and update services, product adoption tracking and analysis services, identity verification services, job applicant tracking and management systems, and software error and bug tracking services.

We do not otherwise reveal your Personal Data to external persons or businesses for their independent use unless: (1) you request or authorize it; (2) the information is provided to comply with applicable law (for example, as compelled by law enforcement to comply with a search warrant, subpoena, or court order, or as required as part of a regulatory filing to securities or other authorities), (3) we need to enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our approved agents, vendors or service providers who perform functions on our behalf; (5) we need to address emergencies or acts of God; or (6) we need to address disputes or claims; or (7) we need to provide such information to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about use of our Platforms and Services and Website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, users, customers, and/or other third parties for marketing or promotional purposes.

Where Personal Data may be transferred

Hiive has its headquarters in Canada. Information we collect about you will be transferred to and processed in Canada. Hiive also processes and transfers Personal Data to the United States and Switzerland for the purpose of enabling our approved third party vendors to provide functionality that is part of the Services, as detailed above under the heading, “Who we share Personal Data with”. By using the Services, you acknowledge that your Personal Data will be processed in the United States, Canada, and Switzerland by Hiive and such approved third party vendors, a full list of which can be obtained by emailing [email protected].

Hiive has entered into appropriate data processing agreement and model clauses with its approved third party service providers, as required by applicable law.

Data storage and retention

Your Personal Data is stored by Hiive on its servers, and on the servers of the cloud-based database management services that Hiive engages, located in the United States. Hiive retains Personal Data for the duration of your business relationship with Hiive and for a period of time thereafter, to analyze the data for Hiive’s own operations, for historical and archiving purposes associated with the Services, and to meet its legal and regulatory obligations to retain information. Subject to these legal and regulatory obligations, all Personal Data that Hiive controls may be deleted upon a verified request from you. For more information on where and how long your Personal Data is stored, and for more information on your rights of erasure and portability, please contact us at: [email protected].

Links to other websites

This Privacy Policy applies only to the Platforms and Services provided by Hiive. The Platforms and Services may contain links to other websites and services not operated or controlled by us (the “Third Party Sites”). The information practices of these Third Party Sites are governed by their own privacy statements. We suggest contacting those Third Party Sites directly for information about their privacy policies. Furthermore, Hiive does not control and is not responsible for any content on the Third Party Sites.

Children’s data

We do not knowingly collect personal information from minors without proper consent from a parent or legal guardian. If you believe that we may have collected personal information from a minor without consent, please contact us at [email protected] and we will properly investigate the issue.

How we secure your Personal Data

Hiive follows industry-standard best practices such as implementing appropriate physical, administrative, and technical controls to protect the confidentiality, security, and integrity of your Personal Data and uses your Personal Data only consistent with your relationship with Hiive and the practices and purposes described in this Privacy Policy.

On the Platforms, all data is encrypted both in-transit and at-rest. Access to sensitive systems, physical or digital, is secured and limited to qualified persons only.

Note, however, that no data transmission over the Internet can be fully guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk.

Changes to this Privacy Policy

We will update this Privacy Policy from time to time by updating this website to reflect any changes to our Personal Data processing practices. Each time you enter or use the Platforms or Services, the current version of this Privacy Policy will apply. If we make any changes to this Privacy Policy that are material, we will notify you at the email address you have provided to us or by publication on this website.

How to exercise your rights

California Residents:

This section applies if you are a California resident and to the extent Hiive’s processing of your Personal Data is subject to the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., and its implementing regulations, and amendments thereto, including the California Privacy Rights Act (“CCPA”).

Hiive acknowledges and agrees that it will process Personal Data only as necessary to provide the Services which constitutes a business purpose. Hiive shall not (i) “sell” or “share” (as defined by the CCPA) your Personal Data that Hiive receives to any third party for monetary or other valuable consideration; (ii) retain, use, or disclose your Personal Data for any commercial purpose (as defined by the CCPA) other than as outlined in this Privacy Policy; or (iii) retain, use, or disclose your Personal Data other than as set out in this Privacy Policy. If you disclose de-identified Personal Data to us, we will not attempt to re-identify any de-identified Personal Data.

You have the right to request certain information about our processing of your Personal Data over the past 12 months. We will provide you with the following details: categories of Personal Data processed, categories of sources from which the Personal Data was collected, the business or commercial purpose for our processing, categories of third parties with whom we have shared your Personal Data, and the specific pieces of Personal Data collected. You also have the right to request deletion of your Personal Data that we have collected about you, subject to the exceptions provided by the CCPA.

To exercise your rights, please use the applicable submission method mentioned below. We will not discriminate against you for exercising your rights under the CCPA.

Residents of the European Union and United Kingdom:

If you are a resident of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or “GDPR”), including as implemented or adopted under the laws of the United Kingdom.

We will process information about you only where we have a legal bases for doing so, including as stated herein. Where required, we have implemented appropriate cross-border transfer solutions to provide adequate protection for transfers of certain personal information, including, but not limited to, the European Commission’s Standard Contractual Clauses (available at https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en). To the extent permitted by applicable law, by using the Platforms and the Services, you consent to the international transfer of information about you to Hiive’s approved third party service providers, who are the sub-processors that are used to provide the Services. A full list of such sub-processors can be obtained by emailing [email protected].

The European Union's GDPR and other countries' privacy laws provide certain rights for data subjects which include the:

1. Right to be informed
2. Right of access
3. Right to rectification
4. Right to erasure
5. Right to restrict processing
6. Right of data portability
7. Right to object
8. Rights related to automated decision making including profiling

If you wish to confirm whether Hiive is processing your Personal Data, please contact us at privacy@hiive.

You may also request information about: the purpose of the processing; the categories of Personal Data concerned; who else outside Hiive might have received the Personal Data from Hiive; what the source of the information was (if you didn't provide it directly to Hiive); and how long it will be stored. You have a right to correct (rectify) the record of your Personal Data maintained by Hiive if it is inaccurate. You may request that Hiive erase that data or cease processing it, subject to certain exceptions. You may also request that Hiive cease using your Personal Data for direct marketing purposes. You may also have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Hiive processes your Personal Data.

When technically feasible, Hiive will, at your request, provide your Personal Data to you. Reasonable access to your Personal Data will be provided at no cost. If access cannot be provided within a reasonable timeframe, Hiive will provide you with a date when the information will be provided. If for some reason access is denied, Hiive will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your Personal Data, you may email us at [email protected]. Alternatively, if you are located in the European Union, you also have recourse to the European Data Protection Supervisor or with your nation's data protection authority.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your data rights, please contact our Data Protection & Privacy Officer:

GDPR Designated Representative

Our nominated EU Representative is: Instant EU GDPR Representative Ltd

1. Adam Brogden
2. [email protected]
3. Tel + 353 15 549 700
4. Instant EU GDPR Representative Ltd
5. 12A Lower Main Street, Office 2, Lucan Co. Dublin Ireland K78 X5P8

Our nominated UK Representative is: GDPR Local Ltd

1. Adam Brogden
2. [email protected]
3. Tel + 441 772 217 800
4. GDPR Local Ltd
5. 1st Floor Front Suite 27-29 North Street, Brighton England BN11EB