Privacy Notice

01. Scope and Website Operator

This Notice applies to personal information collected through ascenvie.com (the “Site”) and to information received when a visitor uses the Site to contact ASCENVIE. For purposes of this Notice, “ASCENVIE,” “we,” “us,” and “our” refer to the ASCENVIE website operator and, where relevant to an inquiry or transaction, affiliated entities or project-specific entities acting with ASCENVIE.

This Notice does not govern personal information processed under a separate privacy notice, contractual arrangement, subscription document, investor portal, employment process, vendor relationship, or other context for which a different notice is provided.

02. Categories of Personal Information We Collect

Depending on how you interact with the Site, we may collect the following categories of information:

• Identifiers and contact information: name, email address, telephone number, and similar contact details.
• Professional or business information: company or organization name, title or role if provided, and information about a business, property, investment, financing, development, partnership, acquisition, or other opportunity you choose to describe.
• Communications and inquiry content: the message and other information you voluntarily submit through the Site or in follow-up correspondence.
• Internet, device, and network information: information ordinarily transmitted when a browser requests a webpage or third-party resource, such as IP address, browser type, device type, operating system, referring URL, timestamps, request logs, and similar technical information that may be processed by hosting, security, content-delivery, or form-processing providers.
• Records of interaction: correspondence, responses, and records reasonably necessary to document a business inquiry or relationship.

The Site does not intentionally request the sensitive categories identified in the notice above. If you voluntarily transmit sensitive information that we did not request, we may delete it, restrict access to it, or retain it only when reasonably necessary for a lawful purpose.

03. Sources of Personal Information

We may obtain personal information:

• directly from you when you complete the Site inquiry form, send an email, call, or otherwise communicate with us;
• automatically from your browser or device as necessary to deliver, secure, and operate the Site;
• from service providers that process Site requests or communications on our behalf; and
• from public or business sources if reasonably necessary to evaluate or respond to an opportunity you initiated, subject to applicable law.

04. Purposes for Collection, Use and Processing

We may use personal information for purposes reasonably necessary and proportionate to the context in which it was provided, including to:

• receive, route, review, and respond to inquiries;
• evaluate potential acquisitions, financings, investments, partnerships, property matters, vendor relationships, and other business opportunities;
• communicate with investors, property owners, counterparties, advisers, service providers, and other business contacts when appropriate;
• operate, maintain, troubleshoot, secure, and improve the Site;
• prevent spam, fraud, abuse, malicious activity, or unauthorized access;
• maintain business, compliance, and correspondence records;
• establish, exercise, or defend legal rights and claims;
• comply with legal, regulatory, tax, audit, litigation-hold, subpoena, court-order, governmental, and other lawful obligations; and
• carry out another purpose disclosed to you at collection or with your direction or consent where required.

We do not intend to collect, use, retain, or disclose personal information in a manner that is materially incompatible with the context in which it was collected without providing any notice or consent required by applicable law.

05. Notice at Collection

The following summarizes the principal categories of personal information collected through the Site, representative examples, and the primary purposes for which they are used.

We retain each category only for as long as reasonably necessary and proportionate for the disclosed purposes, subject to the retention principles described below.

06. Categories of Recipients and Disclosures

We may disclose personal information to the following categories of recipients when reasonably necessary for the purposes described in this Notice:

• Service providers and contractors that support website hosting, DNS, security, email, form processing, communications, storage, and related infrastructure.
• Professional advisers such as attorneys, accountants, auditors, consultants, engineers, architects, brokers, lenders, insurers, and other advisers when relevant to a matter you have raised or to our legal and business obligations.
• Affiliates and project-specific entities when an inquiry relates to an activity conducted through that entity.
• Transaction participants when appropriate to evaluate or pursue a transaction, subject to applicable duties and confidentiality arrangements.
• Governmental, regulatory, judicial, or law-enforcement authorities when disclosure is required or permitted by law, legal process, regulation, subpoena, court order, or to protect legal rights.
• Parties to a corporate or asset transaction in connection with an actual or proposed merger, financing, reorganization, sale, transfer, insolvency, or similar transaction, subject to applicable law.

Disclosure to a recipient does not mean that the recipient may use the information for any purpose it chooses. Service providers are engaged to perform functions for us, although certain vendors may also process limited information under their own terms where applicable.

07. Sale, Sharing and Targeted Advertising

As the Site is currently configured, ASCENVIE does not use personal information collected through the Site for cross-context behavioral advertising and does not sell personal information collected through the Site in exchange for money.

We also do not knowingly sell or share, as those terms are defined by the California Consumer Privacy Act, personal information of individuals under 16 through the Site.

If our practices materially change in a manner that creates a statutory right to opt out of sale or sharing, we will update this Notice and provide the legally required choice mechanism.

08. Cookies, Tracking Technologies and Privacy Signals

The Site is currently designed without ASCENVIE-operated advertising pixels or behavioral-advertising analytics. The Site may, however, request resources from third-party service providers. Those providers may receive technical request information such as IP address, browser or device information, and timestamps as part of delivering their services.

The Site currently uses Google-hosted web fonts and uses FormSubmit to process the public inquiry form. Form submissions are transmitted to FormSubmit for processing and delivery to ASCENVIE. According to FormSubmit’s published documentation, it may retain form submissions for a limited period and its own services may use cookies or other technical mechanisms.

Do Not Track and Global Privacy Control

Because ASCENVIE does not currently engage in cross-site behavioral advertising through the Site, the Site does not provide a separate response to legacy browser “Do Not Track” signals. Where applicable law requires recognition of an opt-out preference signal, including Global Privacy Control, we will process a legally valid signal in accordance with applicable law.

If analytics, advertising, social-media pixels, session-replay technology, or materially different tracking technologies are added in the future, this Notice and any legally required consent or opt-out mechanism should be updated before or at the time those technologies are deployed.

09. Data Retention

We retain personal information only for as long as reasonably necessary and proportionate to fulfill the purposes for which it was collected, including to respond to an inquiry, evaluate or maintain a business relationship, satisfy recordkeeping requirements, preserve relevant business history, resolve disputes, enforce agreements, comply with law, and establish, exercise, or defend legal claims.

Retention periods vary depending on the nature of the information, the relationship, legal or regulatory requirements, applicable limitation periods, litigation or investigation holds, contractual commitments, and the need to maintain accurate business records. When information is no longer reasonably required, we may delete, de-identify, or securely dispose of it, subject to technical backup cycles and legal obligations.

Third-party processors may maintain their own retention periods. FormSubmit currently states in its published documentation that form submissions may be retained by its service for up to 30 days.

10. Information Security

We use administrative, technical, and physical safeguards that we consider reasonable and appropriate to the nature of the information and the context in which it is processed. These measures are intended to reduce risks of unauthorized access, acquisition, destruction, use, modification, or disclosure.

No Internet transmission, email system, website, storage environment, or security measure can be guaranteed to be completely secure. For that reason, sensitive financial, identity-verification, account-access, or other highly confidential information should not be transmitted through the public Site or ordinary email unless an appropriate secure method has been provided.

11. California Privacy Rights

California law provides certain privacy rights to residents when the entity processing their personal information is subject to the applicable statute. To the extent the California Consumer Privacy Act, as amended (“CCPA”), applies to ASCENVIE in a particular context, an eligible California resident may have the right to:

• know or access categories and specific pieces of personal information collected about the resident and information about its sources, purposes, and disclosures;
• request deletion of personal information, subject to legal exceptions;
• request correction of inaccurate personal information;
• opt out of the sale or sharing of personal information, where applicable;
• limit certain uses or disclosures of sensitive personal information, where applicable; and
• receive equal service and treatment and not be unlawfully discriminated against for exercising applicable privacy rights.

The applicability and scope of these rights depend on the circumstances and are subject to statutory exceptions. Nothing in this Notice is intended to provide fewer rights than applicable law requires.

12. Privacy Requests, Verification and Authorized Agents

To submit a privacy request concerning information collected through the Site, contact us at hello@ascenvie.com or call +1 415 320 1448. Please state that your communication is a “Privacy Request” and identify the right you wish to exercise.

We may need to verify your identity before responding to certain requests. Verification information will be used only as reasonably necessary for verification, security, fraud prevention, and compliance. The degree of verification may vary based on the sensitivity of the requested information and the risk of unauthorized disclosure or deletion.

Where applicable law permits use of an authorized agent, we may require evidence of the agent’s authority and may separately verify the identity of the individual on whose behalf the request is made, except where law provides otherwise.

We will respond within the time required by applicable law and may deny or limit a request where a statutory exception applies, the request cannot be verified, or compliance would conflict with another legal obligation. Where required, we will explain the basis for denial.

13. Children’s Privacy

The Site is directed to business and professional audiences and is not designed for children. We do not knowingly solicit personal information from children under 13 through the Site. If we learn that information from a child was submitted in circumstances requiring parental consent or deletion, we will take appropriate steps consistent with applicable law.

14. Third-Party Services and External Links

The Site may use or link to services operated by third parties. Those third parties may process information under their own privacy notices and terms. ASCENVIE does not control the privacy, security, or data-handling practices of an independent third-party website or service.

Current website infrastructure includes third-party form-processing and web-font services. Website hosting, DNS, email, security, and related infrastructure may also be provided by third-party vendors. A vendor’s role, configuration, and privacy practices may change over time, and we periodically may replace service providers.

15. Changes to This Notice

We may update this Notice to reflect changes in law, technology, vendors, Site functionality, or our information practices. The date at the top of the Notice identifies the current version.

If a change is material to how personal information previously collected through the Site is used or disclosed, we will provide any additional notice or obtain any consent required by applicable law before applying the materially different practice.

16. Contact

Questions or requests concerning this Privacy Notice or information collected through the Site may be directed to:

ASCENVIE
San Francisco, California
hello@ascenvie.com
+1 415 320 1448