Last Revised: January 10, 2025

‍INTRODUCTION
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‍Your privacy is important to Dream Ventures LLC (“we” or “us”). This Privacy Policy governs our collection, use, and disclosure of your Personal Data (as defined below) in connection with any websites, mobile websites, or applications owned or operated by us (collectively, “Sites”), including, without limitation, https://www.dreamventures.com and other Platforms (as defined below) that may collect and/or process Personal Data on our behalf; and any other services or business activities we may provide (collectively, “Services”). This Privacy Policy does not apply to Personal Data we collect from or about job applicants, employees, or independent contractors.

By accessing or using the Sites and Services, you consent to the collection, processing, and disclosure of your Personal Data, as set forth in this Privacy Policy. If you do not agree with this Privacy Policy, you must refrain from using our Sites and/or Services

CONTENTS
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1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. JURISDICTION
11. CONTACT US

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1. IMPORTANT INFORMATION AND WHO WE ARE

‍Controller
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‍Dream Ventures LLC is the data controller with respect to the Personal Data described under this Privacy Policy.

‍Changes to the Privacy Policy and Your Duty to Inform Us of Changes

‍We keep our Privacy Policy under regular review and may modify this policy from time to time. If we make any changes to this Policy, we will post the amended terms and change the “Last Revised” date above.It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

‍Children’s Privacy

‍Our Sites and Services are not intended for individuals under 18 years of age, and we do not knowingly collect data relating to children, or direct marketing at children. If we become aware that we have inadvertently received Personal Data from a child under the age of 18, we will delete such information from our records.

‍Third Party Links

‍The Sites and Services may include links to third party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Sites or Services, we encourage you to read the privacy policy of every website you visit.
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2. THE DATA WE COLLECT ABOUT YOU

‍Personal Data

‍We may collect information that personally identifies, relates to, describes, or is reasonably capable of being associated with you (“Personal Data”), including: 

• Identity Data such as first name, last name, LinkedIn profile, Social Security Number, and other government identifiers.
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• Contact Data such as mailing address, telephone number, and email address.
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• Commercial Data such as information provided in response to accredited investor questionnaires, details about products and services you inquired about and/or considered, application versions installed, and/or settings.
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• Demographic Data such as age and gender.

• Financial and Payment Data such as checking and savings routing and account numbers, wire transfer instructions, and other financial account information.
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• Marketing and Communications Preference Data such as your preferences in receiving marketing from us or others and your communication preferences.
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• Communications Data such as copies of chat, text message, mail, and email conversations with us.
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• Geolocation Data such as your approximate geolocation based on indicators from websites or mobile devices or when self-disclosed.
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• Internet and Other Network Data such as IP address, browsing history, search history, and information about your interaction with our Sites, mobile application, or advertisements including technical information about your device and information collected by cookies and similar technologies.
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• Entity Financial Data such as the name, desired credit line, and annual revenue of the entity you are representing.
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‍Business Data
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‍We also collect information about businesses that engage with us such as EIN, TIN, address, phone number, email address, and bank account information (collectively, “Business Data”). This information is generally not considered Personal Data because it relates to a business. If such Business Data relates to a business contact person, we will treat it as Personal Data.

‍Anonymized Data

‍We also collect, use, and share Anonymized Data such as statistical, demographic, aggregated, deidentified, or technical data for any purpose. Anonymized Data could be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate Internet and Other Network Data to calculate the percentage of users accessing a specific website or service feature. However, if we combine or connect Anonymized Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which we use in accordance with this Privacy Policy.

‍Communication Recordings

‍We may record calls and retain the content of text messages, chat transcripts, or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.


3. HOW IS YOUR PERSONAL DATA COLLECTED?


‍Direct interactions

‍We may collect your Personal Data when you communicate with us online or offline, including by filling in forms or by corresponding with us by mail, phone, email, social media, in-person, or otherwise. For example, this includes Personal Data you provide when you inquire about our Services, request marketing communications to be sent to you, complete a survey, give us feedback or contact us. Our service providers may also collect Personal Data on our behalf. You are not required to provide us your Personal Data; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of our Sites or Services or we may not be able to fulfill your requested interaction.Please be aware that Personal Data you share publicly such as via a social media account linked to your use of our Services or in public-facing areas of our Services will be visible to other users and may be collected by them. We are not responsible for, and this Privacy Policy does not apply to, the collection of your Personal Data by any third party.
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‍Automatic Collection

‍We automatically collect information in connection with the actions you take on our Sites (“Usage Data”). For example, each time you use our Sites, we may collect the type of web browser you use, the type of device you use, your device ID, your operating system and version, your IP address, your internet service provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within our Sites, and the duration of your visits to our Sites. If the data we automatically collect is capable of being associated with you, directly or indirectly, we treat it as Personal Data. If this information is not capable of being individually associated with you, we treat it as Anonymized Data.

‍Third-Party Data Sources

‍We may collect Personal Information from third-party data sources such as financial advisors, market data reporting companies, other customers or consumers, and publicly available sources such as government databases.


4. HOW WE USE YOUR PERSONAL DATA

‍We use Personal Data for our business operations when the law allows us to and as outlined below.
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Purposes for which we may use your Personal Data.

“Legitimate Interest”, for processing of data of persons located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“European residents”), means the interests of our business in conducting and managing our business to enable us to give you the best Sites and Services possible and protect our reasonable business concerns. We make sure to consider and balance any potential impact on you (positive and negative) and your rights under applicable law before we process Personal Data of European residents for our Legitimate Interest. We do not process the Personal Data of European residents for our Legitimate Interests if we determine that our interests are overridden by the impact on your rights (unless we have consent or the processing is otherwise permitted by law). If you are a European resident and would like more information about how we assess our Legitimate Interests, you may contact us.

If you are a European resident and the lawful basis for processing your Personal Data is consent, we will obtain consent from you prior to processing your Personal Data for the purpose for which consent is required and you may revoke your consent at any time by contacting us using the contact information below.

‍Change of purpose

‍We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose after we have acquired your Personal Data, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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‍5. DISCLOSURES OF YOUR PERSONAL DATA


‍We may disclose your Personal Data with the following entities:

• Affiliates. We may disclose Personal Data to entities that control us, are controlled by us, or are under common control, for use in a manner consistent with this Privacy Policy. 
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• Service Providers. We may disclose Personal Data to other businesses that provide services to us or on our behalf, such as information technology, research and development, data analytics, and professional and general service providers.

• Government Authorities and Others. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Data and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

• Business Transferees. We may disclose Personal Data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. If a change happens to our business, and you are a European resident, then the new owner of your Personal Data may use your Personal Data in the same way as set out in this Privacy Policy.

‍Third-Party Selling 

‍We do not sell Personal Data to third parties for any purpose, including for marketing their own products or services to you.

‍Investment Management Platforms

We utilize investment management platforms Juniper Square and Carta (collectively, the “Platforms”). When the Platforms collect, store and/or process Personal Data on our behalf, they act as our service provider and are not permitted to use such Personal Data for their own purposes. However, you may also interact with the Platforms outside of their Personal Data collection and processing on our behalf such as when you visit their website or create an online account with them. When you interact with the Platforms outside of their Personal Data collection and processing on our behalf, your interaction will be governed by the privacy policy and terms of use for the relevant Platform. Please review the relevant privacy policy and terms of use before interacting with a Platform. To the fullest extent permitted by law, we disclaim all liability for the acts and omissions of the Platforms.



‍6. INTERNATIONAL TRANSFERS
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Your Personal Data will be processed in the United States of America. If you are a European resident, whenever we transfer your Personal Data out of the EEA we ensure that we have your consent or adequate safeguards are in place as required by the GDPR by either (i) transferring your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission or (ii) using standard contractual clauses approved by the European Commission which give Personal Data a similar amount of protection as it has in Europe, including additional safeguards as needed. Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
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By providing Personal Data to us, you consent to the transfer to and processing of your Personal Data in the United States. Please note that the laws of the United States provide less protection for Personal Data compared to the laws of the EEA.


‍7. DATA SECURITY
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We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect Personal Data from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.


‍8. DATA RETENTION

‍We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation or regulatory inquiry in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.


‍9. YOUR LEGAL RIGHTS

‍Depending on your location you may have additional legal rights related to your Personal Data. We will never discriminate against any person for exercising their legal rights with regard to their Personal Data.

‍European Residents
‍Your Rights

Under certain circumstances, residents of the EEA, Switzerland, or the United Kingdom have rights under EU or national laws in relation to your Personal Information, including the right to:

• Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data when there is no legally valid reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data when you have successfully exercised your right to object to processing (see below), when we may have processed your information unlawfully, or when we are required to erase your Personal Data to comply with local law. However, please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your Personal Data when we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it infringes your fundamental rights and freedoms. You also have the right to object when we are processing your Personal Data for marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
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◦ If you want us to establish the data’s accuracy.
◦ When our use of the data is unlawful, but you do not want us to erase it.
◦ When you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
◦ You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to Personal Data that you provided to us.

• Withdraw consent at any time when we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Sites or Services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising Rights

If you wish to exercise any of the rights set out above, please contact us at:

Email address: compliance@dreamventures.com

Postal address: 3993 Howard Hughes Parkway, Suite 450, Las Vegas, Nevada 89169, United States of America

No fee usually required

You will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
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What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints or Concerns

You have the right to make a complaint at any time to the supervisory authority for data protection issues in the country in which you reside. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
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‍California “Do Not Track” Disclosure

‍Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites do not respond to “do not track” signals.
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‍10. JURISDICTION
‍We are a company located in the United States. All matters relating to privacy issues are governed by the laws of the United States. Nothing in this Privacy Policy will be construed as an admission that we are subject to the laws or jurisdictions of any national or international jurisdiction or governmental entity, or to non-US law.

‍11. CONTACT US
‍If you have any questions regarding this Privacy Policy or our privacy practices, please contact us at the contact information below:

Dream Ventures LLC
Attn: Privacy
3993 Howard Hughes Parkway
Suite 450
Las Vegas, Nevada 89169
compliance@dreamventures.com