Battery Management Corp. – Privacy Notice

This Privacy Notice (the “Privacy Notice”) sets forth the privacy policies of Battery Management Corp. (“Battery Ventures,” the “Company,” “we,” “us”, or “our”) and describes the type of information that Battery Ventures gathers from interactions with prospective portfolio companies, marketing, Battery Ventures events, recruiting channels, and other interactions that refer to or link to this policy, as well as visitors to https://www.battery.com/ (the “Site”) (collectively, the “Activities”).  

By interacting with the Activities (including, but not limited to, the Site), you signify your acceptance of this Privacy Notice. If you do not agree to this Privacy Notice, do not use the Activities.

In addition to this Privacy Notice, Battery Ventures also maintains separate privacy policies, notices, and other related materials including, without limitation, privacy policies and notices maintained in connection with facilitating investment transactions and our employment and recruitment processes (any such policy or notice, the “Other Policies”). In the event of conflict between this Privacy Notice and an Other Policy, such Other Policy shall govern with respect to the applicable subject matter.

Collection, Use, and Sharing of Information

“Personal Information” means any information relating to an identified or identifiable natural person or household. Personal Information may be collected from third parties in order to accurately and efficiently conduct Battery Ventures’ investment program, and other transactions, and comply with legal and regulatory requirements.  The chart below details what Personal Information we collect.

“Company Information” means any information, including but not limited to commercially sensitive and confidential information, that we may receive about a business or organization.

We do not share this information, except as explained below under “Third-Party Contractors,” “Business Transitions,” and “Compliance with Law and Prevention of Harm.”

Third-Party Contractors – We may use contractors (“Service Providers”) to perform limited services on our behalf, such as website hosting platforms, email service providers, payment processors, service providers, fund administrators, attorneys, auditors, administrators, and brokers. Service Providers are required to obtain only the Personal Information they need to deliver the service they were hired to perform, to maintain the confidentiality of Personal Information, and not to use Personal Information for any purpose other than the service they were hired to perform.

Business Transitions and Affiliates – We may share information with businesses that are legally part of the same group as, or that are affiliated entities of, the Company, or that become part of that group. We reserve the right – in the event of a business transition such as a merger – to transfer Personal Information to a new business owner, on the condition that such Personal Information must be treated in accordance with this Privacy Notice.  

Compliance with Law and Prevention of Harm – We may disclose your Personal Information and/or any information submitted via the Activities if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of the Company, our users, yourself or the public.  We may be required to disclose Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We will also disclose Personal Information if a third party directs us to do so, in connection with any government or self-regulatory organization request or investigation, or as otherwise required by law. 

Third Party Content – The Activities may include embedded content (e.g., videos, podcasts, images, articles, etc.) that are linked from other websites. Embedded content is subject to the privacy policies of such websites, rather than this Privacy Notice.

No Sale of Personal Information – We do not sell Personal Information. 

Use, Sharing, and/or Sale of Non-personal Information – We may aggregate data on user behavior with respect to the Activities or de-identify Personal Information such that the Personal Information can no longer be associated with an individual. This data does not enable identification of individual users and is not Personal Information as defined by this Privacy Notice.  As such, our use, sharing, and/or sale of non-personal information is not restricted by this Privacy Notice.

Mobile Numbers and SMS and Text Messaging – If you choose to provide a mobile phone number to our staff directly for the purposes of communicating with us via SMS or text about any business purposes, we will only use your mobile phone number for such conversational, two-way communications that you have consented to or that are legally required for us to engage in.

You may elect to no longer receive communications to your mobile device by contacting us at legal@battery.com or texting “Stop” in response to any message. Your opt-out will be effective after we send you a confirmation.  You will then be placed on our “do-not-contact” list.

No mobile information, including mobile numbers or SMS or text message originator opt-in data and consent, will be shared with third parties or affiliates except where there is a legal requirement to do so or except with your consent.

User Choices with Respect to Personal Information

Users of the Activities may request information about our collection, use, and disclosure of their information (a “Request to Know”), including: 

• the categories and specific pieces of Personal Information we have collected about the user; 
• the categories of sources from which we have collected the user’s Personal Information; 
• the business or commercial purpose for collecting and, if applicable, disclosing the user’s Personal Information; 
• the categories of Personal Information we have sold about the user; and
• the categories of Third Parties with whom we have shared, disclosed for a business purpose, or sold the user’s Personal Information, and which categories of Personal Information we have sold to which categories of Third Parties.

Users may also request (i) that we delete their Personal Information (a “Request to Delete”); (ii) that we correct inaccurate personal information collected from them; (iii) to limit the use and disclosure of sensitive Personal Information collected from them.  While laws such as the CCPA provide users the right to opt-out of the selling or sharing of Personal Information (as those terms are defined under statute), Battery does not engage in those activities.

Requests to Know

Users may submit a Request to Know by emailing us at legal@battery.com or by calling toll free at 1-617-948-3600. 

Users may submit two types of Requests to Know: (1) A request for the specific pieces of Personal Information that we have collected about you in the past twelve months; or (2) a request for the categories of Personal Information that we have collected about you in the past twelve months, and whether we have used and disclosed that Personal Information.  

When you submit a Request to Know, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, and phone number.  If you submit a Request to Know for the specific pieces of information that we have collected about you, we may also require you to submit a signed declaration under the penalty of perjury stating that you are the consumer whose Personal Information is the subject of the Request to Know.  

If we are able to verify your identity, we will respond to your Request to Know by: (a) providing the requested information; or (b) explaining why we are not required to provide the requested information.  If we are unable to verify your identity, we will respond by explaining why we cannot verify your identity.  We will confirm receipt of your Request to Know within 10 days and will respond to your Request to Know within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 45 days.  

If we provide the information requested, we will provide the information free of charge and in a readily useable portable format. We have no obligation to provide Personal Information to you more than twice in a 12-month period. If a Request to Know or series of Requests to Know are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Know, or may refuse to process the Request(s) to Know.

Requests to Delete

Users may submit a Request to Delete by emailing us at legal@battery.com or by calling toll free at 1-617-948-3600. When you submit a Request to Delete, we may ask you to provide certain pieces of information in order to verify your identity, such as your name, email address, phone number, or other identifying documents. If we are able to verify your identity, we will respond to your Request to Delete by (a) deleting your Personal Information and, if applicable, directing any of our Service Providers to delete your Personal Information; or (b) explaining why we are not required to delete your Personal Information. We may choose to delete Personal Information by completely erasing the Personal Information, or by de-identifying or aggregating such Personal Information (in which case, the data resulting from de-identifying or aggregating Personal Information is not subject to a further Request to Delete).  We will specify the manner in which we delete your Personal Information.  

If a Request to Delete or series of Requests to Delete are manifestly unfounded or excessive, we may charge a reasonable fee for processing the Request(s) to Delete, or may refuse to process the Request(s) to Delete. 

Compliance Under U.S. State Comprehensive Data Privacy Laws

To the extent that the California Consumer Privacy Act (CCPA) or its amendments and regulations or any other U.S. state comprehensive data privacy laws apply to the processing of Personal Information, we endeavor to honor your rights as outlined herein and otherwise under such U.S. state comprehensive data privacy laws. Please contact legal@battery.com with any concerns regarding your rights under the CCPA or any other U.S. state comprehensive data privacy laws. We will not discriminate against you for exercising your rights under the CCPA and/or any other applicable U.S. state comprehensive data privacy laws.    

Additional Rights and Information for Users Residing in the European Union, Switzerland, the United Kingdom, and the Cayman Islands

For users outside of the United States, we transfer data from outside countries – including the European Union, Switzerland, the United Kingdom (UK), and the Cayman Islands – to data centers located in the United States for processing. 

European Union and Switzerland

Our processing of Personal Information is intended to be performed in accordance with privacy rights and regulations in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of Personal Information and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”). With respect to direct communications with EU residents, we provide the rights required by the GDPR and rely upon such residents’ consent and our legitimate interests in doing business with such residents. With respect to information we may receive from third-parties regarding an EU resident, we rely upon contractual provisions that are in accordance with the GDPR. Our processing of Personal Information is also intended to be performed in accordance with privacy rights and regulations under the Federal Act on Data Protection of Switzerland of 25 September 2020, as revised on 1 September 2023 (the “FDAP”).

If you are a resident of the European Union or Switzerland, you may have several rights under the GDPR, the FDAP, and/or other applicable local data privacy laws regarding Personal Information, including (without limitation):

• You have the right to request an accounting of all Personal Information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
• You have the right to request that we change any Personal Information that pertains to you.
• You have the right to request that we delete or rectify (to the extent that any data is found to be inaccurate) any Personal Information that pertains to you.
• You have the right to data portability (access to data in a structured, commonly used and machine-readable format, and (if possible) transmission directly to another data controller).
• You have certain rights regarding automated decision-making.
• Switzerland-based residents have heightened rights under the FDAP.

A refusal to provide us with Personal Information may, depending on the purpose for which your Personal Information is required, have various consequences such as us being unable to communicate with you, the termination of any service or other contractual arrangement between us, or, where we have a reasonable suspicion of illegal activity, we may be required to make a report to regulatory or enforcement agencies.

To request an accounting of your Personal Information, a change to your Personal Information, or deletion of your Personal Information, contact legal@battery.com. 

If you have a complaint about our use or processing of your Personal Information, you have the right to lodge a complaint with a national Data Protection Authority. Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm. Contact information for the Federal Data Protection and Information Commissioner (FDPIC) can be found here: https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html. 

United Kingdom (UK)

Our processing of Personal Information is intended to be performed in accordance with the requirements of data privacy laws including Regulation (EU) 2016/679 of the European Parliament and of the Council and the Data Protection Act 2018 (“UK GDPR”).

By providing your information to us, you have agreed to this Privacy Notice and have consented to your Personal Information being stored outside of the UK. 

If you are a resident of the UK, you have several rights regarding Personal Information, including (without limitation):

• You have the right to access your Personal Information and to be informed about how your Personal Information is being used.
• You have the right to request that we delete or rectify (to the extent that any data is found to be inaccurate) any Personal Information that pertains to you.
• You have the right to data portability.
• You have the right to request that we stop or restrict the processing of your Personal Information and to object to how your Personal Information is processed in certain circumstances.
• You have certain rights regarding automated decisions without human involvement. 

However, please note that your right to be forgotten (“erasure”) that applies in certain circumstances under the UK GDPR is not likely to be available in respect of the personal data we hold, given the purposes for which we collect such data, as described above, and the United States regulatory and recordkeeping requirements to which we are subject. 

If you wish to exercise any of these rights or are concerned about how Personal Information is handled, please contact the Battery Ventures Legal and Compliance Department at legal@battery.com. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

Cayman Islands

Our processing of Personal Information is intended to be performed in accordance with the requirements of data privacy laws including the Data Protection Act (2021 Revision) of the Cayman Islands (“DPA”). 

If you are a resident of the Cayman Islands, you have several rights regarding Personal Information, including (without limitation):

• You have the right to access your Personal Information and to be informed about how your Personal Information is being used.
• You have the right to request that we delete or rectify (to the extent that any data is found to be inaccurate) any Personal Information that pertains to you.
• You have the right to request that we stop or restrict the processing of your Personal Information and to object to how your Personal Information is processed in certain circumstances.
• You have the right to require that we cease processing personal data for direct marketing purposes, as well as certain rights regarding automated decisions without human involvement. 

Under the DPA, if you consider that your personal data has not been handled correctly, or you are not satisfied with our responses to any requests you have made regarding the use of your personal data, you have the right to complain to the Cayman Islands’ Ombudsman. The Ombudsman can be contacted by calling 1-345-946-6283 or by email at info@ombudsman.ky.

Protection and Retention of Personal Information

We strive to use commercially reasonable means to safeguard Personal Information and, to that end, restrict access to non-public Personal Information about you to those employees and other persons who need to know the information to enable Battery Ventures to provide services to you.  We maintain physical, electronic and procedural safeguards to protect your non-public Personal Information. The appropriate administrative, physical, and technical safeguards employed by us may vary depending on the nature of Personal Information collected, with more stringent measures applied to information of a sensitive nature. 

However, no method of transmission over the Internet, or method of electronic storage, is entirely secure. Therefore, while we strive to use commercially reasonable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality.  Please be aware that certain Personal Information and other information provided by you in connection with the Activities may be stored on your device (even if that information is not collected by us). You are solely responsible for maintaining the security of your device from unauthorized access, and should always be mindful of the need to maintain secure passwords and other protections to prevent unauthorized disclosures.

Personal Information will be retained for as long as is reasonably necessary to achieve the purposes set forth in this Privacy Notice, consistent with applicable laws and our internal retention policies. The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems. As a minimum, information about you will be retained for the entire duration of any business relationship we may have with you, and for a minimum period of six years after the termination of any such relationship, unless proscribed by applicable law.

Other Provisions

Accessibility and Language – We are committed to making this Privacy Notice accessible to all users. If you require this Privacy Notice in an alternative format — including, without limitation, a format compatible with assistive technology — or in another language, you may request one by contacting us through the “Contact Us” page on the Site or by email at legal@battery.com, and we will provide it free of charge and without undue delay. You may also exercise any of the privacy rights described in this Privacy Notice through the same channels. If you are exercising rights on behalf of another person — including as an authorized agent — please refer to the sections in this Privacy Notice regarding exercising your rights, and we will take reasonable steps to verify your request.

International Users – The Company is located in the United States and processes information through cloud services that may be hosted in various jurisdictions.  Users who choose to access the Activities do so on their own initiative and at their own risk, and are responsible for complying with all applicable laws, rules and regulations. Users who choose to interact with us consent to the use and disclosure of information in accordance with this Privacy Notice and subject to such laws. We may limit the availability of the Activities (including, but not limited to, the Site), in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.  We do not represent or warrant that the Activities, or any part thereof (including, but not limited to, the Site), is appropriate or available for use in any other jurisdiction. 

Children’s Privacy – The Activities are neither directed to nor structured to attract users under the age of 18.  If you are under the age of 18, you are not permitted to participate in the Activities. Battery Ventures does not knowingly collect Personal Information from users under the age of 18. If you are a parent with concerns about children’s privacy issues in conjunction with the Activities, or have reason to believe that we have any such Personal Information, please contact us by email at legal@battery.com, and we will endeavor to delete such Personal Information.

Do Not Track Signals and Collection of Information for Third-Party Advertising – The Company is required to disclose how it responds to “Do Not Track Signals” and whether third parties collect personally identifiable information about users when they use online services.  The Company does not honor “do not track” signals.  However, non-essential cookies and other web tracking technologies are only active after you provide consent via our cookie banner by clicking “accept.” 

Cookies Overview – A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

The following types of cookies are used:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. For example, these cookies record your consent.

• Analytics or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

• Functionality cookies. These cookies are used to recognize you when you return to our website. They allow preferences to be remembered. If you do not allow these cookies then some or all of these services may not function properly.

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. These cookies are sometimes used to track users across websites and in order to deliver ads. If you do not allow these cookies, you will experience less targeted advertising.

The legal basis for any processing of personal data in connection with the use of analytics or performance cookies, functionality cookies or targeting cookies is your consent. You can revoke your consent (if given) at any time. However, such revocation will have no effect on the lawfulness of the processing that took place before you revoked your consent. To revoke your consent, it is sufficient that you delete your cookies and cache from your browser history.

Our Use of Cookies

The table below provides more information about the cookies we use and why:

Necessary

Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.

Functional

Functional cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.

Analytics

Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.

Performance

Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.

No cookies to display.

Advertisement

Advertisement cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns.

Others

Other cookies are those that are being identified and have not been classified into any category as yet.

Third Party Cookies

In addition to the consent management tool, generally web browsers allow users to control many cookies through browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

Amendments – We may modify or amend this Privacy Notice from time to time.  If we make any material changes, as determined by us, to this Privacy Notice, including in the way in which Personal Information is collected, used or transferred, we will post a notice of modification on the Site, which will be effective immediately upon our posting. Your continued use of the Site or interactions with us after any changes or revisions to this Privacy Notice shall indicate your agreement with the terms of such revised Privacy Notice.

Terms and Conditions – Your access to and use of this Site is subject to the Terms and Conditions located at https://www.battery.com/terms-and-conditions/.

Contact Information

If you have questions about this Privacy Notice, please contact legal@battery.com.

Effective Date

The effective date of this Privacy Notice is July 14, 2026.