Privacy Policy

Velvet Sea Ventures Website Privacy Policy

Last modified: October 20, 2021

This privacy policy (“Policy”) describes the manner in which VSV Management, LLC (“Company,” “we,” “us,” “our”) collects, uses, maintains, and discloses information when you visit our website (the “Website”). By accessing or using the Website or any content, functionality, or features contained on the Website, you agree to this Policy. If you do not agree to this Policy, you may not use or access our Website.

Visitors from the European Economic Area, United Kingdom, or Switzerland

If you are accessing our Website from the European Economic Area (“EEA”), the United Kingdom, or Switzerland, please see the section of the Policy below titled International Data Transfers, which describes our collection and use of information obtained from visitors who access our Website from the EEA, the United Kingdom, or Switzerland.

Children Under the Age of 13

Children under the age of 13 are prohibited from using or accessing the Website. Our Website is not intended for or directed at anyone under the age of 13 (or such other age as may be restricted under local law). If we are made aware that we have received information in violation of our Policy, we will use reasonable efforts to locate and remove that information from our records.

If you believe that your child’s information is contained on our Website in violation of this Policy and wish to have it removed, please contact us using our contact information listed below.

Third-Party Links and Websites

Our Website may contain links to other websites.  We may also partner with third parties that may use technologies such as cookies, widgets, and links to gather information about users on our Website.  We do not have control over third party websites and any third party website’s privacy practices are not governed by this privacy statement.  Any time you leave our Website to a third party website or interact with a third party link or other technology, you should exercise caution and review the privacy statement applicable to such websites to learn more.

Collection, Use, and Sharing of Information

We may collect certain information when you use or access our Website. “Personal Information” is information that can be used to identify an individual. Below are specific examples of the Personal Information we may collect.  Personal Information does not include information that has been de-identified or aggregated and that cannot reasonably be used to identify an individual.  We may use, share, transfer, or sell de-identified or aggregated information for any lawful purpose.


Categories of Personal Information We Collect:

  • Identifiers, such as name, date of birth, postal address, e-mail address, telephone number, and internet protocol address that you may provide when using our Website or submitting information to us through our Website.
  • Demographic information, such as nationality or citizenship that you may provide when using our Website or submitting information to us through our Website.
  • Professional or employment information, such as education or work history that you may provide when using our Website or submitting information to us through our Website.
  • Audio, textual, photographic, and/or video content that you may provide when using our Website or submitting information to us through our Website.
  • Internet or other similar network activity, including browsing history, search history, links, and information regarding your interaction with an internet website, application, or advertisement that may be collected with you use or submit information through our Website.
  • Geolocation data may be gathered when users interact with our Website, including IP addresses which provide information about users’ approximate location.

We collect this information:

  • Directly from you when you provide it to us.
  • Through automated technologies, such as cookies, flash cookies, and web beacons, and other interactions with our Website.
  • From our service providers, business partners, and other third parties.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information:

  • To present our Website and its contents to you.
  • To improve the quality, safety, and security of the Website.
  • To provide you with information or services that you request from us.
  • To evaluate, screen, and or respond to inquiries, requests, and information submitted through our Website, including potential investment or employment opportunities.
  • To notify you about changes to our Website.
  • To fulfill any other purpose for which you provide it.
  • For any other purpose with your consent.

Disclosure of Your Information

We may disclose Personal Information that we collect or you provide as described in this Policy:

  • To our subsidiaries and affiliates.
  • To service providers and other third parties we use to support our business or Website.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your Personal Information:

  • To prepare, negotiate, or perform a contract with you;
  • To respond to subpoenas, court orders, or other legal process or otherwise as required by law or the competent government or judicial authorities;
  • To establish or preserve a legal claim or defense;
  • As part of corporate restructuring, sale of assets, merger, or divestiture;
  • To prevent fraud or other illegal activities, such as attacks on our information systems; or
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.

Sale and Marketing of Personal Information

We do not sell your Personal Information to others. We do not disclose any Personal Information to third parties for their direct marketing purposes.

Choices And Access Concerning Your Personal Information

Your choices regarding our use and disclosure of Personal Information

We give you certain choices regarding our use and disclosure of your Personal Information for promotional purposes.  You may opt out from receiving electronic communications from us by contacting us at  If you no longer want to receive promotional-related emails from us, you may opt out according to instructions in such communications.  Please note that if you opt out of receiving marketing-related messages, we may still send you important administrative messages and alerts, including message about any materials or information you submit on our Website.

Access, change, or deletion of Personal Information

To the extent applicable law provides you with the right to review, correct, update, or delete Personal Information that you previously have provided to us, please contact us using our contact information below.  We will respond to your request consistent with applicable law.

California Shine the Light Law

Under California law, California residents have the right to request in writing from businesses with whom they have an established business relationship certain information pertaining to third parties to which the business discloses personal information for marketing purposes. We do not disclose Personal Information to third parties for their direct marketing purposes.

Important Information for EEA, United Kingdom, and Switzerland Users

Contact Information

Company. You may contact us using the contact information provided in this Policy below.

Supervisory Authority. Should you wish to report a complaint or if you feel that we have not addressed your request in a satisfactory manner, you may contact the relevant supervisory authority where you work, normally live or where any alleged infringement of data protection laws occurred. The EU Commission has a list of such supervisory authorities here:

Purposes and Legal Bases for Data Processing

Our purposes and legal bases for processing your Personal Information is described in this Policy.

Automated Decision-Making and Profiling

We may use certain processing and analytical techniques to evaluate requests and inquiries made on our Website. These processing and analytical techniques may constitute automated decision-making and profiling under applicable law. We will not make automated decisions or profiling decisions that may significantly impair your rights unless required by applicable law.

Your Rights

We would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following:

  • Access. You have the right to request us for copies of your personal data. We may charge you a small fee for this service.
  • Rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
  • Erasure. You have the right to request that we erase your personal data, under certain conditions.
  • Restrict Processing. You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • Object to Processing. You have the right to object to our processing of your personal data, under certain conditions.
  • Data Portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
  • Withdraw Consent. You have the right to withdraw your consent to our processing of your personal data at any time.

If you would like to exercise any of these rights, please contact us using the information below. We will respond to your request in accordance with applicable law.

International Transfers

Our administrative offices are based in the United States. When you provide Personal Information to us by using or submitting information on our Website, you expressly consent to the transfer of your Personal Information to our location(s) in the United States. The laws of the United States do not provide legal protection that is equivalent to EU data protection laws. We will employ reasonable technical, administrative, and physical safeguards to protect the Personal Information you provide to us, in addition to safeguarding your Personal Information as provided by this Policy and applicable data protection laws.

To the extent we transfer your Personal Information to another country outside of the EEA, United Kingdom, or Switzerland, we will conduct such transfer in accordance with binding corporate rules, any recognized treaty or trade mechanism, or through the Standard Contractual Clauses.

If you would like more information about international transfers or to obtain a copy of the Standard Contractual Clauses, please contact us using the information below.

Data Integrity

The security of your Personal Information is important to us.  We employ a number of organizational, technical, and physical safeguards designed to protect the Personal Information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the absolute security of your Personal Information. Your submission of any Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Data Retention

We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. The date this Policy was last revised is identified at the top of the page. We encourage you to periodically review this page for updates to this Policy.

Contact Information

To ask questions or comment about this Policy and our privacy practices, contact us at:

VSV Management, LLC, Attention: Legal Department, 801 Northpoint Parkway Suite 129, West Palm Beach, FL 33407, 248-594-4776,