Privacy

SANARA CAPITAL 1 LP PRIVACY POLICY


Last Updated: November 06, 2024


In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Sanara Capital 1 LP (“Sanara”, “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) in connection with www.sanaracapial.com (the “Website”) and Sanara services (the “Services”).


We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.


Table of contents: 




  1. What personal information we collect, why we collect it, and how it is used

  2. How we protect and retain your personal information

  3. How we share your personal information

  4. Your privacy rights

  5. International transfers of personal information

  6. Use by children

  7. Interaction with third party products

  8. Analytic tools/ Cookies

  9. Specific provisions applicable under California privacy law

  10. Contact us



Sanara’s mission is dedicated to A&B financing rounds of Israeli related startups in the health-tech fund industry.



This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.





  1. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED


 




  • We Process the Following Personal Information:





  1. Information provided through the Services. We collect personal information that you voluntarily provide, such as your full name, email address, phone number, home phone, organization name and position, residential address, identification number (ID), signature, nationality and citizenship, place of birth, date of birth, spouses details, tax-related information and details (e.g., tax identification), bank account details, credit history, information about regulatory status, personal information within the forms and any associated documentation that you complete when subscribing for investments, and any other information that you decide to provide us. Providing this information is necessary for us to process your investment subscriptions and manage your account. Without it, we may not be able to offer you our investment services or fulfill your requests. This information is provided voluntarily. However, certain details, such as tax-related information and identification numbers, may be required by law for compliance purposes.

  2. Information provided through the Website. When you use the Website, we collect and process full name, email address, phone numbers, personal inquiries, comments and messages, and any other information that you decide to provide us. This information is used to respond to your inquiries and provide support. If you choose not to provide it, we may not be able to respond to your questions or provide the requested information. Providing this information is voluntary and based on your interaction with our Website.

  3. Information automatically collected. We automatically collect certain information through your use of Sanara’s Website, such as cookie, browser user agent string,  pixels, tracking technologies and similar identifiers (“Technologies”), your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of the Website. This information helps us improve our Website and Services. If you disable cookies or other tracking technologies, some features of our Website may not function properly. This data is collected automatically when you use our Website, and you can manage your preferences through your browser settings.

  4. Information from Other Sources. Sanara also obtains information about you from other sources, including publicly – or commercially- available information, and through third-party data platforms, partners and service providers.

  5. Information you provide to us in person. For example, when you attend one of our events and you provide us with your contact details. This information is used to respond to your inquiries and provide support. If you choose not to provide it, we may not be able to respond to your questions or provide the requested information. Providing this information is voluntary and based on your participation in our events.

  6. Information we collect from online interactions. For example, if you attend a webinar, contact us via social media or otherwise interact with our business, including as a representative of a current / prospective customer, supplier or partner, we track and make a record of those interactions, which may contain your contact details, such as full name, email address, messages and any other information that you decide to provide us with. This information helps us track and improve our interactions with you. If you do not provide it, we may not be able to personalize your experience or follow up on your interactions. Providing this information is voluntary and based on your engagement with our online platforms.





  • We process information for the following purposes:





  1. To provide you with the Services. We will use the information, including, without limitation, for the following purposes: (i) to provide you the Services and to process your requests; (ii) communicate with you about your use of the Services, including, to discuss your investment portfolio; (iii) fulfill any instruction and/or request made by you; (iv) to communicate with you regarding events, meetings, webinars and other activities; and (v) to personalize your experience with our Services; (v) to generally administer and improve the Services.

  2. To allow you to make use of our Website. We will use your information to allow you to make use of our Website, including, (i) to respond to your questions, comments, and other requests for support, or information, including information about potential or future investment opportunities; (ii) to analyze your use of our Website and to improve our Website; and (iii) to customize your experience.

  3. For Administrative Purposes. Sanara uses your information (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future investment options; (ii) to provide you with the Sanara’s Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) to generally administer the Services; (vi)to ensure compliance with applicable laws and or regulations; (vii) managing our risk and operations; and (vii) ensuring internal compliance with our policies and procedures..

  4. To Market our Website and Services. Sanara uses information to market the Services. Such use includes (i) notifying you about portfolio opportunities that may be of interest to you; (ii) conducting market research; (iii) other purposes disclosed at the time you provide information; and (v) as you otherwise consent.

  5. Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Also, personal information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. sending you statements relating to your investment, facilitating the transfer of funds, and administering and facilitating any other transaction, undertaking investor due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors, complying with requests from regulatory, governmental, tax and law enforcement authorities and surveillance and investigation activities.

  6. De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your information and further use it for internal and external purposes, including, without limitation, to analyze and improve Sanara’s services (including through the use of artificial intelligence) and for research purposes. We will use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).

  7. Cookies and Similar Technologies. We use Technologies to automatically collect information through the Website and Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services. If you would like to opt out of the cookies and similar technologies we employ on the Website, you may do so by blocking, deleting, or disabling them as your browser or device permits. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings and learn how to use them, please consult the “Help” function of your browser, or the documentation published online for your particular browser type and version. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Website. The following pages have information on how to change your cookies settings for the different browsers:






  1. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION





  • Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

  • Retention of your information. Your information will be stored until we delete our records, and we proactively delete it, or if you send a valid deletion request. Please note that in some circumstances we store your information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your information or dealings.





  1. HOW WE SHARE YOUR PERSONAL INFORMATION


 


We share your information as follows:




  • The information Sanara gathers is shared with our partners and other third parties.

  • We also share information with our affiliated companies about you.

  • We use third party service providers to process your information for the purposes outlined above, including, without limitation:

    • With cloud service providers for hosting purposes;

    • With websites and web content creation platforms in order to help us manage our Website;

    • With email providers, marketing, CRM, other similar tool providers;

    • With artificial intelligence tools and features;

    • With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy; and



  • To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Sanara, our Services, customers, employees, property, and the public. We may use or disclose the information we collect in order to ensure that our users are complying with all applicable aspects of our policies.

  • We may disclose information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;

  • We may use or disclose the Personal Data to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;

  • If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.

  • Where you have otherwise provided your consent to us for sharing or transferring your information.


 




  1. YOUR PRIVACY RIGHTS

    • The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):




                    i.         You have the right to access the personal information that we hold and request further details about how we process it, under certain conditions.


                   ii.         You have the right to demand rectification of inaccurate personal information about you. We will promptly correct any information found to be incorrect.


                 iii.         You have the right to withdraw consent to the processing, where consent is the basis of processing.


                  iv.         You have the right to request the deletion or erasure of your personal information.



  • You can exercise your rights by contacting us at info@sanaravnetures.com You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee permitted by law, for instance if your request is manifestly unfounded or excessive. If your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.


                                                                             




  1. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION


a)     In order to run our business and provide our Website and Services to you, we transfer personal data to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal data may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever we make such transfers, we will use commercially reasonable efforts to implement an appropriate level of protection to your personal data by implementing at least one of the following safeguards:


        i.    making sure the destination country has been deemed to provide an adequate level of protection for personal data; and/or


       ii.    by executing implement data onward transfer instruments such as data processing and protection agreements.





  1. USE BY CHILDREN. We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@sanaravnetures.com.





  1. INTERACTION WITH THIRD PARTY PRODUCTS. We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.





  1. ANALYTIC TOOLS/COOKIES



  • Through our Services we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day).

  • Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.

  • We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.





  1. CONTACT US. If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@sanaravnetures.com.