EnglishEnglish1.1 Purpose and Principles for Protecting Personal Information
a16z Capital Management Inc (the “Company,” “we,” “us,” or “our”) values the protection of personal information. This Privacy Policy explains how we collect, use, store, share, and protect personal information when providing our products and services, as well as the rights and choices available to you under applicable law.
We process personal information in accordance with the principles of lawfulness, fairness, necessity, and transparency. We limit processing to defined business purposes and implement appropriate safeguards based on the nature of the information involved.
For purposes of this Policy, “personal information” means information that identifies a particular individual, either on its own or in combination with other information, or that relates to a particular individual. Information that has been appropriately anonymized so that an individual cannot reasonably be reidentified is not considered personal information under this Policy, unless applicable law provides otherwise.
1.2 Scope of the Company Website, A16Z QTS App, and Related Services
This Policy applies to the processing of personal information in connection with the operation of the Company’s website and A16Z QTS App, as well as customer applications, eligibility reviews, account management, product support, and business communications.
Different products or features may involve different categories of information. The specific information collected should relate to the services you actually apply for or use. Listing a category of information in this Policy does not mean that every user is required to provide it.
1.3 Individuals Covered and Relationship to Other Agreements
This Policy applies to website visitors, service applicants, eligible professional clients, and authorized representatives, administrators, and other relevant individuals associated with institutional clients.
This Policy describes our personal information processing practices. It does not constitute a commitment to grant access to any product or replace any service agreement. If a particular business activity is subject to a separate privacy notice, that notice should be read together with this Policy. If the provisions differ, the more specific notice applies to the relevant processing activity, without limiting your rights under applicable law.
2.1 Identity and Professional Client Eligibility Information
When you apply for services or act on behalf of an institution, we may collect your name, identity verification documents, employment or position information, authorization documents, and evidence of professional client eligibility, depending on business needs and applicable requirements.
Customer identification or other necessary reviews may require verification of an individual’s identity, authority, or eligibility. When sensitive personal information is involved, we will provide appropriate notices, obtain required authorizations, and implement safeguards in accordance with applicable requirements.
2.2 Registration Details, Account Information, and Permission Settings
During the account application, activation, and use process, we may process account names, account identification numbers, authentication information, permission settings, authorization details, and account status information.
Institutional accounts may involve information about administrators and other authorized individuals. The scope of information processed for each individual should be appropriate to that person’s responsibilities and authorized access.
2.3 Business Applications, Service Usage, and Related Transaction Records
Depending on the features you actually use, we may process application materials, review records, operating instructions, account activity, related transaction records, and service processing information.
Where genuinely necessary for a particular business activity, we may process related financial or settlement information. Such information should be collected only for the stated business purposes and under applicable conditions. You are not required to submit materials unrelated to the services you request.
2.4 Device Information, Login Logs, and Service Communications
To maintain service operations, identify unusual access, and resolve technical issues, we may collect device type, operating system, app version, browser type, IP address, access times, and necessary activity logs.
Text, attachments, and issue descriptions you voluntarily provide when making inquiries or submitting feedback may also become part of our service records. Please avoid including unnecessary identity documents, complete account credentials, or other individuals’ personal information in feedback materials.
3.1 Information You Provide Directly
We may obtain personal information that you voluntarily submit through registration forms, business applications, eligibility reviews, account settings, and service feedback.
At the time of collection, we will explain the information required and its purposes based on the relevant service. Required information is used to complete the applicable review or provide the relevant features. You may choose whether to provide optional information. Failure to provide required information may affect the corresponding service, but should not affect features unrelated to that information.
If your information changes, you should update it promptly so that we can accurately process your applications and account matters.
3.2 Information Automatically Generated by the Website and App
When you visit the website or use the App, the relevant services may automatically generate login, device, access, and activity records to maintain sessions, troubleshoot issues, and protect accounts.
If a feature requires access to device permissions, its purpose should be explained before access occurs, in accordance with the device’s permission mechanisms and applicable requirements. You can manage these permissions through your device settings. Disabling a permission may affect the corresponding feature.
The use of cookies and similar technologies is described in Section 5 of this Policy.
3.3 Information Provided by Authorized Institutional Personnel and Lawful Third-Party Sources
During institutional client applications and related business processes, we may obtain relevant information from authorized institutional personnel, identity verification providers, or other lawful sources.
If you provide us with another individual’s personal information, you should ensure that you have the appropriate authority and provide any notices required under applicable requirements.
When obtaining information from third parties, we will consider its source, intended use, and scope of authorization. We will not treat information as available for unrestricted use merely because it is public or has been provided by a third party.
4.1 Client Eligibility Reviews and Account Activation
We use necessary identity, eligibility, and authorization information to assess whether applicants meet service requirements, verify the authority of institutional representatives, and process account activation, requests for additional materials, and application outcome records.
Submitting an application does not guarantee approval. Providing information does not automatically establish eligibility to use a product.
4.2 Account Permissions and Business Function Support
During the service relationship, we may use account and activity information to manage authentication, feature permissions, business instructions, and account status, and to support the features you are authorized to use.
For institutional accounts, we may rely on valid authorization to add users, modify permissions, or terminate access, and retain necessary records.
4.3 Identity Verification, Compliance Reviews, and Security
Subject to applicable requirements and within the necessary scope, we may use relevant information to verify identities, fulfill legal obligations, identify unusual access, and investigate suspected fraud or unauthorized activity.
The basis for a particular processing activity may include performance of a contract, compliance with legal obligations, your valid consent, or another basis recognized by applicable law. The specific basis should be determined according to the relevant business context.
4.4 Customer Inquiries and Service Issue Resolution
We may use issue descriptions, relevant activity records, and feedback materials you submit to verify circumstances, provide support, resolve disputes, and follow up on outcomes.
If account information or activity logs need to be reviewed, we will limit that review to the information necessary to address the matter.
4.5 Product Evaluation and Service Improvement
We may use necessary usage records, technical logs, or aggregated information to evaluate feature performance, identify operational issues, and improve the product experience.
If we intend to use personally identifiable information for AI model training, profiling, or other purposes beyond those originally described, we should provide a separate explanation in advance and obtain valid consent where applicable. A general statement about service improvement does not constitute blanket authorization for these purposes.
5.1 Use of These Technologies and Categories of Information
The Company’s website or App may use cookies, local storage, or similar technologies to record session identifiers, login status, language preferences, and necessary technical information.
These technologies may be set by the Company or by service providers that deliver particular features. Information about the categories actually used, their purposes, and their retention periods should be provided through the relevant technical disclosures or settings interface.
5.2 Maintaining Login Sessions, Saving Preferences, and Usage Analytics
Essential technologies support authentication, maintain login sessions, and enable basic functionality. Preference technologies save the display or usage settings you select.
If nonessential analytics technologies are used, we will provide relevant information and choice mechanisms in accordance with applicable requirements. Where prior consent is legally required, these technologies should not be activated before valid consent is obtained.
Information obtained through these technologies will be treated as personal information if it can be linked to a particular individual.
5.3 Your Settings and Their Effect on Functionality
You can manage cookies and similar technologies through your browser, device, or other available settings, including deleting stored information or restricting future storage.
Disabling essential technologies may prevent login sessions from being maintained or make certain features unavailable. Your choices regarding optional analytics or preference technologies should affect only the corresponding uses.
After deleting cookies, you may need to select certain settings again. Settings generally need to be managed separately across different devices or browsers.
6.1 Processing by Service Providers and Business Partners
To provide relevant services, we may make information available, as necessary, to providers responsible for technology hosting, identity verification, account support, or other clearly defined service functions.
For providers that process information on the Company’s behalf, we will establish appropriate arrangements addressing processing purposes, confidentiality obligations, security requirements, and information disposal.
If a business partner independently processes information as part of its own responsibilities, we will explain its role and the relevant arrangements as appropriate. A business relationship does not, by itself, justify unrestricted sharing of personal information.
6.2 Regulatory Requirements, Legal Proceedings, and Legally Required Disclosures
Where required or permitted by applicable law, we may disclose necessary information in response to valid regulatory requirements, legal proceedings, or other lawful requests.
We may also process and disclose necessary information to lawfully protect individuals’ rights and interests, investigate suspected unlawful activity, or respond to urgent security incidents. Any disclosure should be appropriate to its specific purpose and legal basis.
6.3 Corporate Reorganizations and Business Transfers
In the event of a merger, acquisition, reorganization, or business transfer, personal information may be reviewed or transferred as part of the relevant business records.
During this process, we will implement appropriate confidentiality and access restrictions and provide notice of relevant changes as required. If the recipient intends to change the original purposes or methods of processing, it should complete any new notice and authorization procedures required by law.
6.4 Limits on Sharing and Recipient Responsibilities
We will limit the categories of information provided and the scope of access according to the sharing purpose, and assess whether the recipient’s involvement in the processing activity is necessary.
If an activity involves information sharing subject to special legal restrictions, the sale of personal information, targeted advertising, or similar practices, the required disclosures and choice mechanisms should be provided separately. The general explanations in this section do not replace those requirements.
7.1 Principles for Determining Storage and Retention Periods
We will determine retention periods for different categories of information based on service needs, account status, applicable recordkeeping obligations, and dispute resolution needs.
Retention periods should be appropriate to the processing purpose. Where a single period cannot be specified, understandable criteria should be used, and the need for continued retention should be reviewed periodically.
Information that must be retained by law will be kept in accordance with applicable requirements. Retention obligations do not automatically end because a user stops logging in or leaves an account inactive for an extended period.
7.2 Retention, Deletion, and Anonymization After Services End
After an account is closed or services end, we may continue to retain records necessary to fulfill legal obligations, address outstanding matters, or protect legitimate rights and interests, while restricting further use.
Information that is no longer needed and has no other lawful basis for retention should be deleted or appropriately anonymized. Anonymization should reduce the possibility that an individual can reasonably be reidentified.
Backup information may be removed gradually according to established replacement cycles. Until removal is complete, appropriate restrictions should prevent its reuse for routine business purposes.
7.3 Cross-Border Processing and Related Safeguards
If service operations, technical support, or business collaboration involve access, transmission, or storage outside the relevant jurisdiction, we will assess the arrangements based on actual data flows.
Where cross-border processing occurs, the relevant jurisdictions, processing purposes, recipient categories, and safeguards should be explained as required, and any necessary contractual, assessment, consent, or other procedures should be completed.
Information protection rules may differ across jurisdictions. Cross-border processing should not reduce the level of protection required by applicable law or constitute a waiver of your statutory rights.
8.1 Access Permissions, Authentication, and Transmission Protection
We will implement reasonable technical and organizational measures based on the nature of the personal information, the scale of processing, and its potential impact. These measures may include appropriate authentication, access controls, transmission safeguards, and activity record management.
Sensitive information and important account operations should receive appropriate protection based on business needs. No technical measure can guarantee absolute security, but the Company remains responsible for fulfilling its applicable information protection obligations.
8.2 Internal Authorization and Confidentiality
Personnel should access personal information only as necessary to perform their duties and comply with applicable authorization, confidentiality, and use requirements.
We will manage permissions according to job responsibilities and adjust access when responsibilities change or personnel leave, reducing the possibility of unauthorized use.
8.3 Service Provider Information Security
When selecting providers that process personal information, we will assess their relevant safeguards in light of the services they provide and the information they can access.
Relevant arrangements should address access restrictions, incident reporting, cooperation obligations, and information handling at the end of the service relationship. Engaging an external provider does not relieve the Company of its legal responsibilities.
8.4 Security Incident Response and Notifications
If we discover that personal information may have been subject to unauthorized access, disclosure, loss, or alteration, we will assess the incident and take appropriate steps to contain its impact, investigate its cause, and address the issue.
Where notification to affected individuals or competent authorities is legally required, we will provide it in accordance with applicable requirements, together with necessary information about the incident and recommended response measures.
8.5 Your Account Security and Authorization Responsibilities
You should safeguard account credentials, avoid sharing them with unauthorized individuals, and promptly update authentication information that may have been compromised or is no longer valid.
Institutional clients should manage personnel authorizations appropriately and promptly adjust permissions when roles change or authorizations end. If unusual activity is detected, a request for assistance should be submitted through an available service channel.
9.1 Access, Correction, Deletion, and Copies of Information
Subject to applicable law and relevant conditions, you may have the right to understand how your personal information is processed, access relevant information, correct inaccuracies, request deletion, or obtain a copy.
Some jurisdictions may also provide data portability or other related rights. The specific rights available depend on your location, the categories of information involved, and the Company’s obligations.
9.2 Withdrawal of Consent and Other Applicable Choices
Where processing relies on your consent, you may withdraw that consent using the applicable method. Withdrawal generally does not affect the lawfulness of processing previously carried out based on valid consent.
Where applicable conditions are met, you may also request restrictions on or object to particular processing, or opt out of information sharing and other activities for which applicable law provides an opt-out right.
Merely visiting the website, reading this Policy, or continuing to use services should not be treated as blanket consent to every purpose for which personal information may be processed.
9.3 Submitting, Verifying, and Handling Rights Requests
You may submit requests through the account management features or privacy request channels actually available within the relevant services. An institutional representative acting on another person’s behalf should provide necessary proof of authorization.
To protect information security, we may request identity verification materials proportionate to the request. We should not collect information that clearly exceeds what is necessary for verification.
We will handle requests within applicable time limits. If an extension is legally necessary or a request cannot be fully fulfilled, the reasons should be explained, along with any applicable options for review, appeal, or submitting a complaint to a competent authority.
9.4 Legal Retention Obligations and Other Applicable Limitations
We may be unable to delete all information immediately if it is subject to statutory retention requirements, relates to unfinished business or dispute resolution, or has another lawful basis for retention.
Where applicable, we will restrict uses that are no longer necessary and explain what action can be taken. You should not receive adverse treatment prohibited by applicable law because you exercise your privacy rights.
10.1 Minors and Third-Party Services
The A16Z QTS App is intended for eligible institutional and professional clients and is not directed to minors.
If we discover that personal information about a minor has been collected inadvertently, we will take appropriate steps to verify the circumstances, restrict its use, or delete it, in accordance with applicable requirements. Professional client eligibility reviews do not replace legally required age-related protections.
The website or App may contain third-party links or access points to independent services. Information processing independently conducted by third parties is generally governed by their own privacy policies. The Company remains responsible for fulfilling its applicable obligations when it provides information to a third party.
10.2 Policy Updates, Notices of Changes, and Version Management
We may update this Policy to reflect changes in business features, information processing practices, or applicable requirements, and provide the revised version through relevant pages or in-service notices.
If a change concerns important matters such as processing purposes, the scope of sharing, or user rights, we will provide notice in a manner appropriate to its impact.
Where renewed consent is legally required, it should be obtained before the relevant processing begins. Policy updates should not be used to retroactively authorize previously undisclosed uses of information.
10.3 Effective Date and Supplemental Regional Provisions
The effective date and most recent update date should be clearly identified in the published version of this Policy. Each version applies according to its stated date, and version records will be retained as necessary.
If a jurisdiction imposes additional personal information processing requirements, the Company will explain them through applicable regional supplements or specific notices.
If this Policy conflicts with mandatory requirements of applicable law, those requirements prevail. This Policy does not exclude or limit any rights that cannot lawfully be excluded or limited.
