TERMS OF USE AND PRIVACY POLICY
General
Please read the following terms and conditions (inclusive of the Privacy Policy, the “Terms”). They govern your use of this website (the “Site”) and its associated services, including Aro-affiliated newsletters, podcasts, social media and other content, whether distributed via this website or other content distribution platforms (collectively with the Site, the “Services”). By accessing or using the Services in any manner, you agree to be bound by the Terms. We may update the Terms from time to time, and any modifications will be effective immediately upon posting unless we indicate otherwise. If you use the Services after any modifications have been posted, your use will constitute your agreement to such modifications. We suggest that you review these Terms periodically for changes.
Except as otherwise noted on the Services, all content and material on the Services – including information, photos, podcasts, blog or social media posts, videos, graphics, icons, design and overall appearance – are the property of Aro Ventures, LLC (“Aro,” "Aro Ventures," “we” or “us”) and should not be used, modified or reproduced without our prior written consent. All trademarks, trade names and logos displayed on the Services are the property of Aro, its affiliates or their third-party owners, and the Services grant no license to them.
The Services are intended solely to provide general information related to Aro. The Services are not directed at and should not be relied upon by any investor or prospective investor in any investment fund or other investment vehicle managed by Aro. Aro does not intend to solicit or make its investment advisory services available to the general public.
Under no circumstance should any information provided via the Services be considered an offer soliciting the purchase or sale of any security or other interest in any investment fund or other investment vehicle managed or mentioned by Aro, nor should any such information be construed as an offer to provide investment advisory services. Any such offer or solicitation will be made separately and only by means of confidential offering documents specific to the relevant investment fund or other investment vehicle to investors that, among other requirements, meet certain qualifications under federal securities laws. There can be no assurance that Aro’s investment strategies will be successful or that Aro’s investment objectives will be achieved. Any investment in a fund or other investment vehicle managed by Aro involves a high degree of risk, including the risk of a complete loss of investment.
Any Aro portfolio companies or other investments described or referenced via the Services are not representative of all investments of the funds managed by Aro, and there can be no assurance that the investments described or referenced will be profitable or that future investments will have similar character or results.
Any opinions expressed via the Services reflect the views of the individual posters and are subject to change. Certain information available via the Services has been obtained from third-party sources, including from portfolio companies of investment funds managed by Aro. While taken from sources we believe are reliable, Aro has not independently verified all such information, and Aro makes no representation or warranty about the accuracy of such information or its suitability for any purpose. The opinions expressed via the Services are not intended to constitute investment, accounting, tax or legal advice; nothing in the Services is a recommendation that you purchase, sell or hold any security or other investment or that you pursue any particular investment strategy. The content available via the Services is presented on an “as is” basis without any warranty, express or implied, of any kind.
Certain statements made or other information disseminated via the Services by individual Aro personnel may constitute “forward-looking statements” under the Privacy Securities Litigation Reform Act of 1995. To the extent any information made available via the Services constitutes a forward-looking statement (which may be identified by use of forward-looking terminology such as “may,” “will,” “should,” “expect,” “anticipate,” “upside,” “potential,” “project,” “estimate,” “intend,” “forecast,” “target,” “believe” or similar terminology), please note that actual events, results or performance may differ materially from those reflected or contemplated by such statement. Aro disclaims any obligation to update any forward-looking statement in the event it later turns out to be inaccurate, whether as a result of new information, future events or otherwise. Any projections, estimates, forecasts, targets or opinions expressed via the Services are subject to change without notice and may differ from opinions expressed by others.
Past results of Aro’s managed investment funds or other investment vehicles are not necessarily indicative of future results.
Third-Party Websites
The Services may include content created, prepared or otherwise made available by third parties or a link to or integration with websites operated by third parties and such third party content may be subject to additional terms and conditions. Aro has no control over any such content or websites and shall have no liability related to such content or websites. The existence of any such content, link or other integration does not constitute an endorsement of the relevant content, website or third party. You hereby release and hold Aro harmless from any and all liability arising from your use of any third-party content, website or service.
Restrictions on How You Use the Services
You represent, warrant, and agree that you will not provide or contribute anything to the Services, or otherwise use or interact with the Services, in a manner that:
infringes or violates the intellectual property rights or any other rights of anyone else; violates any law or regulation, including, without limitation, any applicable export control laws, privacy laws or any other purpose not reasonably intended by Aro; is dangerous, harmful, fraudulent, deceptive, threatening, harassing, defamatory, obscene, or otherwise objectionable; attempts, in any manner, to obtain the password, account, or other security information from any other user; violates the security of any computer network, or cracks any passwords or security encryption codes; runs Maillist, Listserv, any form of auto-responder or “spam” on the Services, or any processes that run or are activated while you are not logged into the Services, or that otherwise interfere with the proper working of the Services (including by placing an unreasonable load on the Services’ infrastructure); “crawls,” “scrapes,” or “spiders” any page, data, or portion of or relating to the Services or Content (through use of manual or automated means); copies or stores any significant portion of the Content; or decompiles, reverse engineers, or otherwise attempts to obtain the source code or underlying ideas or information of or relating to the Services.
A violation of any of the foregoing is grounds for termination of your right to use or access the Services.
Limitation of Liability
TO THE FULLEST EXTENT ALLOWED BY APPLICABLE LAW, UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY (INCLUDING, WITHOUT LIMITATION, TORT, CONTRACT, STRICT LIABILITY, OR OTHERWISE) SHALL ANY OF THE ARO PARTIES BE LIABLE TO YOU OR TO ANY OTHER PERSON FOR (A) ANY INDIRECT, SPECIAL, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES OF ANY KIND, INCLUDING DAMAGES FOR LOST PROFITS, BUSINESS INTERRUPTION, LOSS OF DATA, LOSS OF GOODWILL, WORK STOPPAGE, ACCURACY OF RESULTS, OR COMPUTER FAILURE OR MALFUNCTION, (B) ANY SUBSTITUTE GOODS, SERVICES OR TECHNOLOGY, (C) ANY AMOUNT, IN THE AGGREGATE, IN EXCESS OF ONE-HUNDRED ($100) DOLLARS OR (D) ANY MATTER BEYOND OUR REASONABLE CONTROL. SOME STATES DO NOT ALLOW THE EXCLUSION OR LIMITATION OF INCIDENTAL OR CONSEQUENTIAL OR CERTAIN OTHER DAMAGES, SO THE ABOVE LIMITATION AND EXCLUSIONS MAY NOT APPLY TO YOU.
Privacy Policy
At Aro, we respect your privacy and, whether you are visiting the Site as an investor, founder or member of the general public, you are entitled to the protection of your personal information. Please read this Privacy Policy to learn how we treat your personal information.
By using or accessing the Services in any manner, you hereby consent to our collection, use and sharing of your information as described in this Privacy Policy. Remember that your use of the Services is subject to the Terms, including this Privacy Policy.
1. What this Privacy Policy Covers.
This Privacy Policy provides important disclosures and other information relating to how we treat Personal Data that we gather when you access or use the Services, but this Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage, nor does this Privacy Policy cover the practices of any entity with whom we have an investment relationship, even if you are able to access such entity’s website or services through a link on the Site. This Privacy Policy also does not apply to information obtained or disclosed in offline correspondence or in connection with an investment in one of our affiliated investment funds. Please note that you may have additional rights to control the use and disclosure of your Personal Data. Residents of California should refer to the relevant subsections below. If you have a disability, you may access this Privacy Policy in an alternative format by contacting info@aro.ventures.
Use of the term “Personal Data” herein means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.
2. Categories of Personal Data We Collect.
The below identifies the categories of Personal Data that we have collected over the past 12 months or may collect in the future:
Category of Personal Data
Examples of Personal Data We May Collect
Categories of Third Parties With Whom We May Share this Personal Data:
Profile or Contact Data
First and last name
Email address
Service Providers
Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide
Identifying information in your emails, letters, submissions or other communications directed to us
Service Providers
Parties You Authorize, Access or Authenticate
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
When you provide such information directly to us.
When you use the Services.
When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
When you send us an email or otherwise communicate with us.
When you use the Site and such information is collected automatically.
Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
Third Parties
Vendors
Third parties may help us provide you with customer support.
Our Commercial or Business Purposes for Collecting Personal Data
Providing, Customizing and Improving the Services
Providing you with the Services you request.
Meeting or fulfilling the reason you provided the information to us, including to deliver our newsletters and emails and to facilitate events.
Communicating with you about the Services, including Services announcements.
Providing support and assistance for the Services.
Improving and developing the Services, including research, testing and internal analytics.
Protecting against, deterring or otherwise addressing fraud, security and debugging.
Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or required, and sending you information related to us.
Sending emails and other communications according to your preferences or that display content that we think will interest you.
Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable laws, rules and regulations, court orders and other applicable legal requirements.
Protecting against, deterring or otherwise addressing illegal, fraudulent or otherwise harmful actions and maintaining the safety, security and integrity of the Services.
Enforcing any agreements with you.
Responding to claims that any content available via the Services violates third-party rights.
Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
3. How we Share Your Personal Data.
We may disclose your Personal Data to the categories of service providers or other parties identified in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:
Hosting, communications and other technology providers, including providers that help us manage newsletter signups and email services and for event registration.
Parties You Authorize, Access or Authenticate
Third parties you access through the Services.
Legal Obligations
We may share any Personal Data that we collect with third parties in furtherance of the purposes described under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services, provided that we will not share such data in a manner that could identify you.
4. Tracking Tools and Opt Out.
The Services may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable the relevant servers to recognize your web browser and tell us how and when you visit and use the Services, to analyze trends, learn about our user base and operate and improve the Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or other device when you use that device to access certain of the Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because we may use Cookies, the Site does not support “Do Not Track” requests sent from a browser at this time.
We may use the following types of Cookies:
Essential Cookies. Essential Cookies may be required for providing you with features or services that you request. Disabling these Cookies may make certain features and services unavailable.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To obtain more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.
5. Security and Retention.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, and administrative security measures and storage and processing practices based on the type of Personal Data. For example, the Site uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. We retain Personal Data about you for as long as necessary to provide the Services to you, comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data or storing data over the Internet is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
6. Personal Data of Minors.
We do not knowingly collect or solicit Personal Data about children under 16 years of age. If we learn that we have collected personal information from an individual under 16 years of age without parental consent, we will delete such information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at info@aro.ventures.
7. Privacy Rights of California Residents.
If you are a resident of California, you have the rights set forth in this section. If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@aro.ventures.
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including the:
Categories of Personal Data that we have collected about you. Specific pieces of Personal Data that we have collected about you. Categories of sources from which that Personal Data was collected. Business or commercial purpose for collecting your Personal Data. Categories of third parties with whom we have shared your Personal Data. Categories of Personal Data shared with third parties for a business purpose over the past 12 months, if applicable.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you, subject to certain exceptions under the CCPA: for example, we may need to retain your Personal Data to provide you with the Site or services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your CCPA Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Data or are an agent authorized by that person, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You may submit a Valid Request by emailing us at info@aro.ventures.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
We Do Not Sell Your Personal Data
We will not “sell” your Personal Data, as that term is defined in the CCPA, and have not done so over the last 12 months. We also do not sell the Personal Data of minors under 16 years of age.
We Will Not Discriminate Against You for Exercising Your Rights under the CCPA
We will not deny you access to our Site or provide you a lower quality of services if you exercise your rights under the CCPA. If you have any questions about this section or whether any of the above rights apply to you, please contact us at info@aro.ventures.
8. Privacy Rights of Other United States Residents.
California Resident Rights
California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, under California Civil Code Sections 1798.83-1798.84. If you would like to submit such a request, please contact us at info@aro.ventures.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. If you are a Nevada Resident, you can exercise this right by contacting us at info@aro.ventures with the subject line “Nevada Do Not Sell Request” and providing us with your name. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
9. Privacy Rights of European Union and United Kingdom Residents
The Site is hosted and operated in the United States (“U.S.”) by us and through our service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (collectively, the “GDPR”) with respect to your Personal Data, as outlined below. By using the Site, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the U.S. and will be hosted on U.S. servers, and you authorize us to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. We will be the controller of your Personal Data processed in connection with your use of the Site.
If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@aro.ventures.
Personal Data Collection, Use and Disclosure
The “Categories of Personal Data We Collect” subsection of this Privacy Policy above details the Personal Data that we may collect from you, and “How We Share Your Personal Data” details how we may use or disclose your Personal Data.
Legal Basis for Processing
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
Contractual Necessity: We may process Personal Data as a matter of “contractual necessity”, meaning that we may need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Site and our services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Site that require such data.
Legitimate Interest: We may process the following categories of Personal Data when we have a legitimate interest that is not outweighed by your privacy rights: Profile or Contact Data Other Identifying Information You Choose to Provide We may also de-identify or anonymize Personal Data to further our legitimate interests.
Consent: In some cases, we may process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
EU and UK Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
For more information about these rights, please email us at info@aro.ventures.
Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
16. Changes to This Privacy Policy.
We’re constantly trying to improve our Site and services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on our website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Site and/or services, and you are still responsible for reading and understanding them. If you use the Site and/or services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
17. Contact Information.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, or your choices and rights regarding such collection and use, please do not hesitate to contact us at info@aro.ventures.