Privacy Policy

Introduction

The Hiive Company Limited and its affiliates (“Hiive”) provide services that help users buy and sell stocks in late-stage, venture-backed companies. We do so primarily through our online platform at hiivemarkets.com (the “Hiive Platform”). In order to deliver these services efficiently, securely and in compliance with law, we will have to collect and handle information about natural persons like yourself.

We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy describes Hiive's policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

How we use personal information

As is true of most other websites, Hiive's website and the Hiive Platform collects certain information automatically and stores it in log files. The 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 usage information about the use of Hiive's website, including a history of the pages you view. We use this information to help us design our site to better suit our users' needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. We also use Google Analytics solely to track your browsing session's movement within hiivemarkets.com.

Hiive has a legitimate interest in understanding how visitors and potential customers use its website. This information assists Hiive with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet customer needs.

Hiive platform users

For users who want to sign up for and use the Hiive Platform, we will need to collect and process more of your personal information. With a few exceptions, this information generally is limited to: full name, job title, employer name, home address, business address, email address, phone number, date of birth. We may also ask for a copy of, or any information contained on, a piece of government-issued identification such as a driver's license or passport.

We use this information for five main purposes:

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.

Hiive has legitimate interests in collecting this information: to provide and improve the Hiive services, to securely authenticate your access to the Hiive Platform, to prevent fraud, to update you on relevant activity on the Hiive Platform, and to meet Hiive’s legal obligations under applicable law.

Cookies and tracking technologies

Hiive uses cookies or similar technologies to analyze trends, administer our website, 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, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or Hiive Platform.

Reasons we share personal information

We do not sell personal information 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 Hiive's services and the Hiive Platform, 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. We use contracts and undertake diligence to ensure that these third parties provide at least the same level of protections that Hiive provides for your personal information. The services we use at this time are:

We do not otherwise reveal your personal data to non-Hiive persons or businesses for their independent use unless: (1) you request or authorize it; (2) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), 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; (3) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (4) to address emergencies or acts of God; or (5) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about 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 information may be transferred

Hiive has its headquarters in Canada. Information we collect about you will be transferred to and processed in Canada. Hiive also collects and transfers personal data to the United States for the purpose of data sub-processing by the vendors identified above. By using Hiive’s services, you acknowledge that your personal information will be processed in Canada and the United States.

Hiive endeavors to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with Hiive and the practices described in this Privacy Policy. Hiive also enters into data processing agreements and model clauses with its vendors whenever feasible and appropriate.

How to access and control your personal information

The European Union's General Data Protection Regulation (GDPR) and other countries' privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

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

This Privacy Policy is intended to provide you with information about what personal data Hiive collects about you and how it is used. If you wish to confirm that Hiive is processing your personal data, or to have access to the personal data Hiive may have about you, 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 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 data for direct marketing purposes. In many countries, you 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 time frame, 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 can email us at [email protected] Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation's data protection authority.

Data storage and retention

Your personal data is stored by the 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 service data for the duration of the customer’s 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 Hiive’s 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 verified request from a 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]

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 and we will investigate the issue.

Data security

Hiive follows industry-standard best practices to protect your personal information. On the Hiive 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.

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