Privacy Policy
and Terms of Use

Banneker Partners LLC (“Banneker”) is committed to respecting and protecting the privacy of the personal information it collects. Please read this privacy policy carefully to understand what information Banneker collects and how it uses and when it discloses to others that information. This privacy policy applies to information collected (i) from you via this website (bannekerpartners.com) and other Banneker-affiliated websites and online services that link to this policy; (ii) from you when you interact with Banneker on phone or video calls, at events, as part of Banneker-sponsored programs, or in other contexts; and (iii) from “third party” sources in the course of managing its portfolio of investments and consideration of new investments, as described below.

If you are an investor in a Banneker fund, then our investor privacy notice, such as that required by the Gramm-Leach-Bliley Act of 1999, is also applicable to you.

What Personal Information Do We Collect?

Banneker and third parties working on our behalf collect personal information that you provide directly to us. The specific information you provide is typically a function of the context in which you provide it; for example, we collect information from you when you register for an event, or when you submit certain professional background and other contact information related to potential candidacies for jobs at Banneker. With your consent, we may record or otherwise collect information about the speakers and attendees at Banneker-sponsored webinars or on phone or video calls with Banneker personnel. In addition, we may collect information about you from third-party sources, including but not limited to publicly available information (e.g., social media platforms like LinkedIn or company websites), references you provide to us, and other sources of information about the companies and markets in which we invest.

The personal information we collect may include, but is not limited to:

• Contact information and other identifiers (for example, name, address, phone number, e-mail address, social media identifier, name of your employer, your position or title, other professional information about you and your career, information about your prior communications with employees of Banneker, and other data you may provide us so that we can contact you).
• Internet activity information (for example, “cookies,” web server logs, web beacons, and other electronic tools to collect statistical information about your use of this website and other websites). For more information about how we collect and process such information, please see our “Cookie Policy” below.
• Context-specific information.
• Other personal information you may provide, which may be publicly available, or that we may acquire through third-party sources.

In addition, if you live in the United States, we may collect demographic or ethnicity information to monitor compliance with applicable non-discrimination laws. You do not have to submit this information. Moreover, if you have submitted this information and given us consent to use the information, you may withdraw your consent at any time. If you wish to withdraw your consent, please contact us at admin@bannekerpartners.com

How Do We Use and Share Your Personal Information and Other Information?

Banneker and third parties working on our behalf use the information we have about you for internal business purposes, such as managing our portfolio of investments, overseeing our business and client relationships, communicating with you, responding to your requests, enhancing our services, compiling aggregate statistics, and improving this website. In addition, we may record webinars or phone or video calls to create transcripts that we use to help train our employees, agents, associates, or partners, on the best ways to conduct or engage in such communications, or we may use information you provided over this website to send you more information about Banneker and the services we can provide. To assist us with these activities, information covered by this privacy policy, including information about your use of this website, may be combined with or enhanced by other information that we have from other online or offline sources. With respect to information collected from third parties, Banneker primarily uses and/or discloses this information to learn more about you and your company as part of its consideration of potential employment, partnership, or investment opportunities.

Finally, we may disclose your information with third parties as permitted or required by law, including:

• With service providers that assist us in operating our business;
• To comply with the law or in response to a subpoena, court order, government request, or other legal process;
• To produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings;
• To protect the interests, rights, safety, or property of Banneker or others;
• To enforce any terms of service or other legal disclosures on or related to this website;
• In connection with a sale or other transfer of all or some of the assets of Banneker and/or in connection with a sale or merger of Banneker or any division of Banneker;
• To provide you with the services or products requested by you, and to perform other activities related to such services and products;
• To operate Banneker’s systems properly; or
• Any other sharing, with your consent.

Note that, except in cases where the party with which Banneker has disclosed information is operating on behalf of Banneker, this privacy policy does not apply to, and Banneker is not responsible for, the treatment of the information by those third parties, including any Banneker portfolio companies that may receive such information.

We do not sell your personal information to third parties.

What Are Banneker’s Lawful Bases for Processing?

Some jurisdictions require that organizations have a “lawful basis” for processing or sharing any personal information. Banneker has several lawful bases for using and sharing the information we collect for the purposes outlined above. Specifically:

• Banneker has a legitimate business interest in ensuring that its website continues to function efficiently and effectively, and to enhance the functionality of the website in response to how visitors use the website.
• When you submit contact information to receive communications from us, or when you submit professional background or other similar information, Banneker uses that data to fulfill your request.
• When you direct us to disclose information to one or more of our portfolio companies, such as when you wish to be considered for active employment, partnership, or investment opportunities, Banneker uses the data to fulfill your request.
• Banneker has a legitimate business interest in using the data it collects, including recordings of webinars and phone or video calls, to train its employees, agents, associates, and partners and improve our ability to serve our investors and portfolio companies.
• Banneker has a legitimate interest in using data about the individuals who visit its website and the companies for which they work to cultivate business relationships that may benefit Banneker or our portfolio companies.
• Banneker may need to perform such processing for compliance with applicable legal requirements or to assert legal rights or defenses.
• To the extent that certain processing activities, or the processing of certain data, requires us to seek your consent, we have done so.
• Banneker has a legitimate interest in using data from public sources to learn about companies in which we may want to invest or work with, and the individuals who manage those companies.

Cookie Policy

As described above, Banneker, third parties working on our behalf, and our partners, including social networking sites, may also place, view, and/or use cookies, web server logs, web beacons, and other electronic tools to collect statistical information about your use of this website and other websites. Such information may include your device’s IP address, browser type, operating system, computer platform, web pages viewed, the date and time of your visit, the links you click within this website, the websites used prior to visiting this website, and whether you have been to this website before. Banneker or such third parties may use such information either on behalf of Banneker or for the other parties’ own purposes, including research and analysis, to enhance your experience with this website, to provide you with certain functions on this website, to create aggregate and anonymize information about usage of this website and other websites, etc. Banneker may also combine such information with information we collect from other sources, such as company websites and social media, to identify potential opportunities for partnership with other companies. Banneker has a legitimate interest in cultivating and building the business-to-business relationships made possible by such data processing.

The collection, use, and disclosure of the information by third parties is governed by their own privacy policies and is not the responsibility of Banneker. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information.

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or how to disable the collection of geo-location data. You need to set each browser, on each device you use to access the internet. Similarly, if you connect to the internet from multiple devices (e.g., work and home), you need to set each browser on each device. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of this website will not function properly.

Security

To protect your personal information from unauthorized access and use, we use reasonable administrative, technical, personnel, and physical measures. These measures include computer safeguards and secured files and offices.

Data Retention

We will retain your personal information for as long as needed for the purposes described herein, or as otherwise required by law.

Links to Third-Party Websites

This website may contain links to third-party websites, including social networking sites and the websites of Banneker’s portfolio companies. Since we do not control these third-party websites and are not responsible for any information you may provide while on such websites, we encourage you to read the privacy policies on those websites.

Accessing and Updating Your Personal Information

To access, review, rectify, or delete your name, e-mail address, phone number, or physical address, or your business name, business e-mail address, business address, or business phone number Banneker has collected about you that is subject to this policy, please contact us at admin@bannekerpartners.com. Please include the following information in all requests: first name, last name, and e-mail address. While Banneker will make reasonable efforts to fulfill your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.
Transferring Personal Information to Other Countries
Banneker primarily stores the information described above in the United States. You should only submit information to Banneker if you are comfortable that your data will be stored in the United States as part of our effort to fulfill your request. In some circumstances, such as when Banneker collects data from third parties, Banneker uses Standard Contractual Clauses or other lawful mechanisms to comply with requirements that may apply to any transfer of information to the United States.

Some of the uses and disclosures mentioned in this privacy policy may involve the transfer of your personal information to various countries around the world that may have different levels of privacy protection than your country. By submitting your personal information through this website, you acknowledge the possibility of such transfers for the purposes described in this privacy policy.

Your Rights Under Certain Data Privacy Laws

European Union and United Kingdom Residents

If you are viewing this website from the European Union or United Kingdom (UK), under the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 and other legislation (“UK GDPR”) you have a number of rights with regard to your “personal data” (as defined in the GDPR or the UK GDPR). For example, you have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing and (in certain circumstances) the right to data portability. If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time; however, such withdrawal will not affect the lawfulness of the processing before your consent was withdrawn. You also have the right to lodge a complaint if you believe that we have not complied with the requirements of the GDPR or the UK GDPR regarding your personal data.

Likewise, if you are a resident of the Cayman Islands, the Cayman Islands’ Data Protection Law, 2017 provides you with certain rights as regards your personal information.
To learn more about these rights, make a request for your information, or to lodge a complaint with respect to your personal data, please contact us at admin@bannekerpartners.com.

California Residents

If you are a resident of California, please review our California Privacy Notice (“Notice”) set out below, which explains the types of personal information we collect that are subject to the California Consumer Privacy Act, as amended (“CCPA”), as well as your rights under the CCPA.

CCPA Notice

This Notice is for California residents and supplements our privacy policy. It explains how we collect, use, and disclose your Personal Information and how to exercise your rights under the CCPA. This Notice applies to (i) personal information collected via this website (bannekerpartners.com) and other Banneker-affiliated websites and online services that link to the policy; (ii) to information that we collect from you when you interact with Banneker on phone or video calls, at events, as part of Banneker-sponsored programs, or in other contexts, as described below; and (iii) to information that Banneker collects from other “third party” sources in the course of managing its portfolio of investments and consideration of new investments.

If you are an investor in a Banneker Fund, then our investor privacy notice is applicable to you and the information we may collect in the course of providing financial services to you.

Note that when we say “Personal Information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.

How We Collect, Use, and Disclose Personal Information

When you use our website, participate in certain Banneker-sponsored programs or otherwise interact with us, we may collect certain Personal Information about you.
We do not sell or share any of your Personal Information.
The best way to learn about the kinds of information we collect and how we use it is to review the entirety of our privacy policy. The following is a summary of the CCPA-related categories of Personal Information we may have collected about you in the 12 months preceding the effective date of this notice, as well as the purpose for which this Personal Information may have been collected and to whom we may have disclosed it.

Categories of Personal Information We May Have Collected About You

• Identifiers, which may include name, address, phone number, and e-mail address;
• • Characteristics of protected classifications under California or federal law, such as race, ancestry, national origin, religion, age, mental and physical disability, sex, sexual orientation, gender identity, medical condition, genetic information, marital status, or military status;
• • Internet activity information, which may include cookies, web server logs, web beacons, and other website tracking information or user activity;
• • Audio, electronic, visual, thermal, olfactory, or similar information;
• • Professional or employment-related information, which may include employment history, occupation, title, and employer information;
• • Education information not considered publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act; and
• • Inferences that can create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

Some of the information we collect about you, such as racial or ethnicity information, may be considered “sensitive personal information” under CCPA.

The business purposes for which we may have collected your Personal Information include:

• Communicating with you;
• Responding to your requests;
• Marketing to you;
• Organizing and conducting surveys or assessments sponsored by us on behalf of our portfolio companies;
• Improving or enhancing our services;
• Enhancing the functionality of our website;
• Training our employees, agents, associates, and partners;
• Promoting systems and data security;
• Providing a platform for our portfolio companies to identify qualified employment candidates;
• Monitoring compliance with applicable non-discrimination laws; and
• Performing other business purposes.

Parties to which your information may have been disclosed include:

• Third parties and service providers that perform services on our behalf;
• Banneker portfolio companies, when you have directed us to disclose information to them, such as to consider you or your company for employment, partnership, or investment opportunities; or
• Law enforcement or other third parties in connection with legal requests or as required by law.

We have disclosed personal information to such third parties consistent with the business purpose(s) for which the information was collected, as described above.

Note that we will not disclose, and have not disclosed, to Banneker portfolio companies any sensitive personal information, though we may disclose anonymized and aggregated data derived from such information.

Sources of Personal Information

The categories of sources from which we collect or receive Personal Information include you, your device(s), Banneker portfolio companies or affiliates, third parties or services providers that provide service to you or perform services for us on our behalf, and publicly available sources.

How You Can Exercise Your Rights Provided Under the CCPA

Under the CCPA, you have the following rights if you are a resident of California:

• Right to Know: You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices;
• Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you;
• Right to Request Deletion: You have the right to request that we delete your Personal Information that we have collected from you;
• Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.

To exercise any of these rights, please contact us at admin@bannekerpartners.com or at (415) 758-4177.

Please note that to protect the integrity of our services and to protect your privacy interests, we will need to verify your identity before processing your request. We may need additional information to verify your identity and that your state of residence is California, if you choose to provide it. This could include: a driver’s license, permit, utility bill, subscription stub, mail, school ID card, or school record.

Under the CCPA, you may exercise these rights yourself or you may designate an authorized to make these requests on your behalf. If you choose to have an authorized agent act on your behalf, we may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.

We do not sell your personal information to third parties, nor do we knowingly collect, sell or share the personal information of individuals under the age of 16.

Certain Exceptions Under the CCPA

As alluded to above, certain types of Personal Information are exempt from certain requirements of the CCPA. This includes:

• Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (and implementing regulations), or pursuant to the California Financial Information Privacy Act;
• Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate governed by the privacy, security, and breach notification rules issued pursuant to the Health Insurance Portability and Accountability Act of 1996, as amended;
• Personal information collected from a job applicant, employee, owner, director, staff member, officer, or contractor when the information is used in the context of the person’s role as a job applicant, employee, owner, director, staff member, officer, or contractor; and
• Personal information about an employee, owner, director, officer, or contractor of another business that is collected in connection with providing or receiving a product or service to or from the other business.

Covered business have limited obligations, or in some cases no obligations, under the CCPA with regard to these types of personal information.

How We Respond to Do Not Track Signals

Some web browsers may give you the option to request that a website operator not track your information across its website or other websites using the browsers’ “Do Not Track” settings. At this time, we do not respond to “Do Not Track” browser settings or requests, and we will only use your information in a manner consistent with this privacy policy.

Modifications to This Privacy Policy

Banneker reserves the right to modify this privacy policy at any time by posting the revised version on this website and updating the effective date. Such changes will be effective upon posting. We encourage you to check this website frequently to see the current privacy policy in effect and any changes that have been made to it.

Questions Regarding This Privacy Policy

If you have additional questions regarding this privacy policy, please contact us at admin@bannekerpatners.com.