The Venture Codex: Privacy Policy

Effective Date: September 22, 2025

Last Updated: May 29, 2026

1. NOTICE AT COLLECTION

At or before the time of collection, we are notifying you that Magid and Company, LLC ("we," "us," or "our") collects the categories of personal information listed in Section 2 for the business purposes described in Section 4. We do not "sell" your personal information for monetary or other valuable consideration, nor do we "share" your personal information for cross-contextual behavioral advertising purposes as defined by California law.

2. CATEGORIES OF PERSONAL DATA COLLECTED

We collect any information that identifies, relates to, or could reasonably be linked to a particular individual. In the preceding 12 months, we have collected (and reserve the right to collect) the following categories of data from any source available to us:

Category	Examples (Including but not limited to)
A. Identifiers	Name, alias, IP address, email, social media identifiers, account names, or unique personal identifiers.
B. Commercial Info	Records of products/services considered or purchasing tendencies within the Service.
C. Professional Info	Job history, investment history, board seats, and professional credentials.
D. Network Activity	Browsing/search history, interactions with the Service, and "anti-scraping" device fingerprints.
E. Geolocation Data	Physical location or movements (typically derived from IP address).
F. Inferences	Profiles reflecting preferences, characteristics, psychological trends, and aptitudes.
G. Sensitive Info	Account log-in credentials or other data categorized as sensitive under applicable law (used primarily for security/verification).

3. SOURCES OF DATA COLLECTION

We collect data from all available sources, including but not limited to:

Directly from you: Through account registration, profile updates, and direct communications.
Automated Technologies & Web Scraping: Using proprietary scripts and automated tools to harvest data from the public web, server logs, and device fingerprinting.
Public Articles: From news media, press releases, social media platforms, and government records (e.g., SEC filings).
Third-Party Sources: From data brokers, professional networking sites, and licensed data partners.

4. USE OF PERSONAL DATA (Business Purposes)

We use Personal Data for the following Business Purposes only:

Core Operations: Maintaining the Service and our proprietary "Profiles" database.
Marketing & Communications: Sending communications regarding the Service and Magid and Company, LLC.
Affiliate Coordination: Sharing data with our affiliate, Finalis Securities LLC, for the business purpose of providing requested financial insights and maintaining regulatory compliance.
Security & Enforcement: Detecting fraud, protecting intellectual property, and enforcing anti-scraping provisions.
Research & Analysis: Creating aggregated, de-identified datasets for internal use or commercial licensing.

5. DATA SHARING AND DISCLOSURE

We do not sell or share your information with third parties for their own independent commercial use. We disclose data only to:

Affiliates: Specifically Finalis Securities LLC, acting under common control for our internal business purposes.
Service Providers: Vendors performing tasks on our behalf (e.g., hosting, analytics) who are contractually prohibited from using your data for any other purpose.
Public Profiles: Information in the "Profiles" section of the Service is, by design, shared with all users of the Service.
Legal/Succession: To comply with law or as an asset in a merger, sale, or acquisition.

6. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

No Sale/No Share

Because we do not sell or share your personal information (as defined by California law), we do not provide a "Do Not Sell or Share" link.

Right to Know/Delete

California residents may request access to or deletion of their personal account data.

Statutory Exceptions to Deletion

We reserve the right to deny deletion requests where the data is necessary to: (i) protect our proprietary intellectual property (Profiles); (ii) comply with legal obligations; or (iii) perform actions solely for internal purposes that are reasonably aligned with consumer expectations.

7. NON-US USERS NOTICE

The Service is hosted in the United States and intended for US residents. By using the Service, you acknowledge that your data will be processed in the US. We do not intentionally target or monitor residents of the EU or UK.

8. DATA RETENTION

We retain Personal Data for as long as we deem necessary to fulfill our business purposes, maintain the integrity of our historical "Profiles" database, and protect our legal rights.

9. GOOGLE USER DATA (GOOGLE API SERVICES)

When you choose to connect your Google account to the Service, we access a limited set of Google user data through Google APIs, and only after you grant consent on Google’s authorization screen. We request read-only access only. The Google data we access is:

Google Calendar events (read-only): to detect meetings with funds and investors, populate first and next meeting dates, and display meeting evidence on records in your workspace.
Google Contacts (read-only): to suggest people in your network and identify potential warm introducers to funds and investors.
Your Google account email address: to identify the connected mailbox and label the source of the synced data.

How We Use and Protect This Data

We use Google user data solely to provide the Calendar and Contacts features described above to you and the members of the workspace you connect the account to. Synced meeting and introducer information is visible to other members of that workspace. Google user data is stored encrypted. You can revoke our access at any time by disconnecting your Google account within the Service or through your Google Account settings, after which we stop syncing new data.

Limitations on Use (Carve-Out)

Google user data is obtained only through the Google APIs with your consent. The provisions of this Privacy Policy regarding web scraping, third-party data sources, data brokers, commercial licensing, marketing, and affiliate sharing (including Sections 3, 4, and 5) do not apply to Google user data. We do not sell Google user data, use it for advertising, transfer it to data brokers, or use it to develop, train, or improve generalized artificial intelligence or machine learning models. We do not allow humans to read this data unless we have your affirmative consent, it is necessary for security purposes (such as investigating abuse), or it is required to comply with applicable law.

Limited Use

The Venture Codex’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.

10. CONTACT

Magid and Company, LLC

Email: codexfeedback@magidandco.com

The Venture Codex

by Magid & Co