Privacy Policy

Introduction

The Hiive Company Limited and its affiliates (“Hiive”, “we”, “us”, or “our”) help users buy and sell stocks in late-stage, venture-backed companies primarily through our online platform at hiivemarkets.com (the “Platform”) and associated products and services (collectively, the “Services”). 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 (or “user”) 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 the Platform, this Privacy Policy is incorporated into the 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, Hiive's website (the “Website”) and the Platform 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 Platform, including a history of the pages you view.

We use Google Analytics solely to track your browsing session's movement within hiivemarkets.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 Platform 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 Platform use cookies and similar technologies to analyze trends, administer our Website and the Platform, track users' movements around the website, 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 Platform. As well, there is not yet a commonly accepted industry standard for this type of technology. As such, 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 and potential customers use the Website and Platform. This information assists Hiive with providing more relevant products and services and with ensuring appropriate staffing to meet customer and website visitor needs.

Other Personal Data collected through the Hiive website

If you use the Website in order to sign up for a demo of the Platform or apply for a job, Hiive will 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 enable the demo and consider your application for employment, respectively.

Hiive has a legitimate interest in collecting this information in order to provide you with the demo to better understand the Services and address its staffing needs.

Hiive Platform onboarding

For users who want to create an account on and use the Platform, we will need to process additional Personal Data. With a few exceptions, this information generally is limited to: full name, job title, employer name, home address, business address, email address, phone number. Depending on the purpose for which you intend to use the Platform, 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 Platform. 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 of processing this information is to facilitate your transaction, provide feedback on your postings (such as on list price), and to ensure that transactions and negotiations on the Hiive platform are bona fide, comply with Hiive’s terms and conditions, and do not breach relevant securities laws.

Hiive Platform activity and transactions

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

The purpose of processing this information is to facilitate your transaction, provide feedback on your postings (such as on list price), and to ensure that transactions and negotiations on the Hiive 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 Platform, ensure that the Platform is effective, and monitor and track activity on the Platform in order to meet Hiive’s legal obligations under applicable law.

There are five main purposes for our processing of information on the Platform 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 identity, and running anti money laundering checks.
2. To communicate with you about your use of the Hiive Platform, 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. Generally speaking, your identity is anonymized throughout your interactions on the Hiive Platform; however once you enter into a messaging interaction with another user or accept a bid, some of your personal information (including name and email address) may be shared with the counterparty.
4. To collect data about and track your usage of the platform, 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.
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 also process any Personal Data as required by applicable law, regulatory authorities, or legal process.

Limited Purpose

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 Platform or buying or selling private securities.

Who we share Personal Data with

We do not sell Personal Data to anyone and only share it with third parties who are facilitating the delivery of our Services as described below.

From time to time, Hiive receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from a third-party website (e.g. LinkedIn).

We use a number of third parties to power the Website, Platform, 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 absolutely necessary to provide the functions we have described below. We use 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 are:

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 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

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].

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 Services provided by Hiive. The 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 priv[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 Platform, 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 use the 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

The European Union's General Data Protection Regulation (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 [email protected].

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