Please do not send any information to NEA that constitutes a trade secret or is confidential or proprietary. NEA cannot agree to obligations of confidentiality or non-disclosure with regard to information submitted to it. By submitting information or materials to NEA, you or anyone acting on your behalf, agree that any such information or materials will not be considered confidential or proprietary.
Effective Date: 12/02/2021
Last Updated: 12/02/2021
For all California residents, please refer to New Enterprise Associates (“NEA”)’s California Consumer Privacy Act Privacy Notice, which may be found below.
New Enterprise Associates and its corporate affiliates (referred to collectively in this Policy as “NEA,” “we,” “us,” “our,” and similar pronouns) knows that your privacy is important to you, and we want you to know that it is important to us too. We created this Policy to explain the types of information we collect through www.nea.com and careers.nea.com, and the various social networking platforms that we use (each, a “Site”), how we will use, disclose and protect this information once it is collected, and how you can opt-out of some of our uses and disclosures of your information. The Site also links to website and portals that are operated by third parties or are limited to NEA’s limited partners. These include portal.nea.com, neaconnect.mobilize.io, and nea.getproven.com (referred to collectively as “Restrictive Sites”).
This Policy does not apply to our limited partners, who can find their applicable Privacy Notice, EU Privacy Notice or their Regulation S-P Privacy Notice in the Investor Portal.
Here are a few general principles to keep in mind as you read through this Policy:
- As our business evolves, this Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.
- This Policy does not apply to information that you may provide to us, or that we may obtain, other than through our Site, such as over the phone, by mail, by e-mail, by electronic data room or in person.
- Cookies are small data files stored on your computer or device at the request of a Web site. A cookie assigns a unique numerical identifier to your Web browser, and may enable us to recognize you as the same user who was at our Site in the past, and relate your use of the Site to other information about you, such as your Site usage information and Personal Information. Cookies may also be used to enhance your experience on the Site (for example, by storing your username so you can log in easily, keeping you logged into the Site after you have provided your password, and storing the contents of your shopping cart as you browse) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features.
- A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you’ve opened one of our emails or seen one of our Web pages.
- enabling users to use our Site and its features
- administering the Site and your account with us, including verifying approved access to the Restricted Site
- responding to your requests, questions, and concerns
- market research and better understanding our audience
- developing new features and offerings on the Site
- increasing the functionality and user-friendliness of the Site
- protecting our rights and property
- recovering debt and preventing fraud
- alerting you to our financial products or services
- other purposes disclosed when Personal Information is submitted to us
- when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law.
- in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business. In addition, we may share non-personally identifiable Site Usage Information (including aggregate data) with others, for their own use, in a form that does not include your name or contact information.
- the right to request access to the Personal Information we hold about you,
- the right to have inaccurate information about you amended or updated,
- the right to object to processing of Personal Information about you,
- the right to withdraw consent at any time (where relevant),
- the right to have Personal Information about you erased or to restrict processing in certain limited situations,
- the right to data portability and to request the transmission of Personal Information about you to another organization,
- the right to object to automated decision making that materially impacts you, direct marketing, and processing for research or statistical purposes, and
- the right to lodge complaints with applicable data supervisory authorities.
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Directly from you. For example, from forms you complete or products and services you purchase.
- Indirectly from you. For example, from observing your actions on our Website.
- Third party vendors that provide databases.
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a service, we will use that information to provide that service to you. We may also save your information to facilitate future communications and services.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
- Firms that provide assistance in servicing NEA and that have a need for such information, such as CRMs or other service providers.
- Service providers.
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Calling us at 1-410-842-4000
- Emailing us at: email@example.com
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- An email address that operates as a user log-in, name, and date of birth.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
- Calling us at 1-410-842-4000
- Emailing us at: firstname.lastname@example.org
What information is collected on this Site?
“Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information. We collect different categories of Personal Information from different sources, including User-Provided Information and Site Usage Information. We also may collect Personal Information from social networking and blogging.
We collect Personal Information such as your name; Company name; e-mail addresses; telephone numbers; ISP account addresses (including text message addresses); and site browsing history. For example, we may collect Personal Information such as your e-mail address, or any other information you may choose to provide, when you submit a comment or question to us through the Site. We may also collect names or other types of Personal Information from you when accessing the Restrictive Sites to help verify that you are authorized to access the Restricted Sites.
Site Usage Information
As is the case with many web sites, our servers automatically collect your IP address when you visit our Site, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your Site usage. Clickstream data includes, for example, information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next Web site you visit when you leave the Site, and any search terms you have entered on the Site or a referral site.
Among other things, this information enables us to generate analytics reports on the usage of our Site. To opt-out of your Site usage being included in our Google Analytics reports, you may follow these instructions: https://tools.google.com/dlpage/gaoptout
In addition, we may deploy various tracking technologies on the Site to collect additional information about your Site visits. For example:
These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number or identifier to you, and relate your Site Usage Information to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access our Site using different Web browsers and different computers or devices.
We maintain a presence on social networking and blogging platforms, some of which are operated by third parties, such as LinkedIn, Facebook, and Twitter. This Policy applies to our use of information you submit to us there, but it does not apply to what those third party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.
How is your information used?
We or our service providers may use the Personal Information we collect from and about you, including User-Provided Information, Site Usage Information and/or any information collected through Social Networking sites, to perform the following business functions:
To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Site Usage Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Site, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.
Do we share Personal Information and Site Usage Information with others?
Yes. We may share the information we collect on the Site with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with third parties who need your information in order to provide services to us (or on our behalf), we may share your information:
Do Not Track Disclosures
Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices (which are explained in more detail under “Site Usage Information” above) in response to DNT settings in your web browser.
Our third party partners, such as Google Analytics, collect information about your online activities over time and across our Site and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser and we do not obligate these parties to honor DNT settings. We utilize Google Analytics for our web analytics and you can opt out of your Site usage data being included in our Google Analytics reports by visiting https://tools.google.com/dlpage/gaoptout
While we endeavor to protect the security and integrity of sensitive Personal Information collected via this Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely error-free or safe from intrusion by others, such as hackers. We do not warrant or represent that the Site’s level of security meets or exceeds any particular standard, and any information you submit via the Site is at your own risk.
If you correspond with us by e-mail, text message, or using a “contact us” feature on our Site, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
If at any time during or after our relationship we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you. We will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us.
“Linked-To” Web Sites
The Site may contain links, banners, widgets or advertisements that lead to other Web sites. We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each Web site visited after leaving the Site to learn about how your information is treated by others.
Data Subject Rights Under European Law
If you are a natural person (a “Data Subject”), you may have certain rights in addition to those described elsewhere in this policy. These rights are in relation to your Personal Information, and include the right to be informed about the collection and use of your Personal Information, as outlined in this Policy.
Such rights may also include, where certain conditions are met:
As a Data Subject, you should use the contact information below to get more information and/or to make a formal request. We will endeavor to keep the Personal Information we store about you reasonably accurate and up-to-date by enabling you to correct it by request.
You should notify us if any of your Personal Information changes or if you become aware of any inaccuracies in the Personal Information we hold about you.
Legal Basis for Processing Personal Information
We use the Personal Information collected from Data Subjects where it is necessary for us to perform under an agreement with you (if we have one with you) and for our legitimate interests where your interests and fundamental rights as a Data Subject do not override those interests. For example, in order for us to operate our Web Site, it is necessary for us to collect certain data about you to improve your user experience and manage the Site. In addition, we use this Personal Information to send informational messages to you to the extent allowed by applicable law.
Disclosure & Retention of Data Subjects’ Personal Information
We will take reasonably necessary steps to ensure that where Personal Information of Data Subjects is shared with third parties, it is treated securely and in accordance with this Policy and applicable laws.
We will endeavor not to keep Personal Information in a form that allows a Data Subject to be identified for any longer than is reasonably necessary for achieving the permitted purposes. At the end of the applicable retention period, we may destroy, erase from our systems, or anonymize Personal Information as part of such efforts. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of the Data Subject’s Personal Information, the purposes for which we process the Data Subject’s Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Storage & Transfer of Data Subjects’ Personal Information
We maintain physical, electronic and procedural safeguards designed to protect Data Subjects’ personal information, prevent unlawful or unauthorised processing of personal information, and prevent unauthorized disclosure of, or accidental loss of, or damage to, such information.
We may process personal information in, and transfer personal information to, countries that may not guarantee the same level of protection for personal information as the country in which Data Subjects reside.
Personal information will also be processed by staff who work for us and operate outside the European Economic Area. This includes staff engaged in, among other things, the provision of administration and support services. All such staff are subject to appropriate confidentiality and security obligations.
We restrict access to non-public personal information about Data Subjects to those of our employees and agents who need to know the information to enable us to provide services.
We will only transfer personal information to third party service providers if they agree to comply with the physical, electronic and procedural safeguards described above, or if they put in place adequate measures themselves.
In the event that you wish to make a complaint about how your personal data is being processed by NEA (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with your domestic supervisory authority and NEA’s data protection representative, Langham Hall Group, at [GDPR-UK@langhamhall.com] [verify email with Langham Hall].
We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page with a new “Effective Date” and a new “Last Updated Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you. In some cases, we may request your consent to the changes.
If you have any questions or comments regarding our privacy practices, you may contact us at:
1954 Greenspring Drive Suite 600, Timonium, MD 21093 United States
T: (410) 842-4000 Toll Free: 1-877-507-6425 Email: email@example.com
Privacy Notice for California Residents
Effective Date: 12/02/2021
Last Reviewed on: 12/02/2021
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information”). Personal information does not include:
In particular, we have collected the following categories of personal information from our clients and investors within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We do not sell your personal information. We may use or disclose the personal information we collect for one or more of the following purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we make efforts to ensure that the recipient will both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, NEA has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category H: Sensory data.
Category I: Professional or employment-related information.
We disclose your personal information for a business purpose to the following categories of third parties:
Sales of Personal Information
In the preceding twelve (12) months, NEA has not sold personal information.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:
We do not provide these access and data portability rights for B2B personal information.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Website and update the Notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Or by mail at:
1954 Greenspring Drive
Timonium, MD 21093