Privacy Policy

1. Who we are

SportTech Gem Holdings (“we”, “us”, “the firm”) is a venture capital investment firm with its office at 5000 Stadium Way, Suite B, Los Angeles, CA 90001, United States. We are the controller of the personal information described in this policy. You can reach us at contact@sporttechgem.com or on +1 310 555 0912.

This policy covers https://sporttechgem.com and the correspondence that follows from it. It does not cover the internal handling of personal information in companies we invest in, each of which is a separate controller, nor the websites of third parties we link to.

2. What we collect

We collect very little, and almost all of it is given to us deliberately.

• Information you submit through the enquiry form Your name, email address, company or organisation, the subject category you select, the content of your message, and the fact that you ticked the consent box. Anything else you choose to include in the message field is collected as part of that message.
• Information you send by email or telephone Where you contact us directly, we hold that correspondence and any attachments, including pitch materials and financial information you choose to send.
• Limited technical information Our web server records the requested URL, a timestamp, HTTP status, referring page and user-agent string. IP addresses are truncated before storage and used only for aggregate traffic counting and to investigate abuse or outages.
• Cookie preference If you accept or decline the cookie notice, that choice is stored in your browser using local storage so we do not ask again. It stays on your device and is not transmitted to us.

We do not run advertising pixels, cross-site trackers, session recorders or third-party analytics products that build profiles across websites. We do not buy contact lists, and we do not enrich enquiries with data from third-party providers.

3. Why we use it, and on what basis

We use the information you send us to evaluate a company, to respond to a limited partner or press enquiry, to keep a record of who we have spoken to and what we said, and to meet our own record-keeping and anti-money-laundering obligations as a manager of pooled investment vehicles.

Where the EU or UK General Data Protection Regulation applies to you, our lawful bases are: your consent, for the enquiry form; our legitimate interests in assessing investment opportunities, maintaining relationships and securing our infrastructure; and our legal obligations, for tax, anti-money-laundering and regulatory record-keeping. Where we rely on legitimate interests, you may object and we will stop unless we have compelling grounds to continue.

4. Who sees it

Enquiries are read by the investment team and, where relevant, by our finance and compliance function. We share personal information outside the firm only in the following circumstances:

• with service providers that operate our email, file storage, website hosting and customer relationship records, under written contracts that restrict them to processing on our instructions;
• with professional advisers — counsel, auditors and fund administrators — where they need it to advise us;
• with co-investors or syndicate members, where you have asked us to introduce you to them or where a round we are participating in requires shared diligence, and only with your knowledge;
• where we are required to disclose by law, court order, or a regulator with jurisdiction over us.

We do not sell personal information, and we do not share it for cross-context behavioural advertising. Some of our service providers are located outside your country; where personal information moves out of the European Economic Area or the United Kingdom, we rely on the European Commission’s standard contractual clauses or the UK international data transfer addendum.

5. How long we keep it

Enquiries that do not lead to a further conversation are deleted within twenty-four months. Records relating to companies we met more than once are held for the life of the relevant fund plus seven years, because we may need to demonstrate how and when a decision was made. Server logs are retained for ninety days. Correspondence subject to statutory record-keeping is held for the period the relevant law requires and no longer.

6. Your rights

Depending on where you live, you may have the right to ask us for a copy of the personal information we hold about you, to correct it, to delete it, to restrict or object to how we use it, to receive it in a portable format, and to withdraw consent at any time without affecting processing that already happened.

California residents have specific rights under the California Consumer Privacy Act as amended by the California Privacy Rights Act, including the right to know the categories of personal information collected and the purposes for collection, the right to delete, the right to correct, and the right not to be discriminated against for exercising those rights. Because we do not sell or share personal information as those terms are defined in that statute, there is nothing to opt out of, but you may still make a request and we will confirm this in writing.

To exercise any of these rights, write to contact@sporttechgem.com. We will verify your identity, usually by confirming details of an existing exchange, and respond within forty-five days, extendable once where a request is complex. There is no charge for a reasonable request.

7. Security

The site is served over HTTPS. Internal access to enquiry records is limited to staff who need it, protected by single sign-on with multi-factor authentication, and reviewed periodically. Devices are encrypted at rest. No system is perfectly secure, and we ask that you do not send confidential rights-holder agreements, athlete personal data or other sensitive material in a first email; we will tell you when a secure channel is available.

8. Children

This site is intended for professional audiences and is not directed at children. We do not knowingly collect personal information from anyone under sixteen. If you believe a child has sent us information, write to us and we will delete it.

9. Changes

If we change this policy we will update the date at the top of the page. Material changes affecting how we use information already collected will be communicated directly to the people concerned where we hold contact details for them.

10. Complaints

If you are unhappy with how we have handled your information, please tell us first — most issues are resolved quickly. You also have the right to complain to a supervisory authority: the California Attorney General for California residents, your national data protection authority in the European Economic Area, or the Information Commissioner’s Office in the United Kingdom.