Privacy Policy & Terms of Use

Last Updated: March 11, 2026

CVC Manager, LLC (hereinafter, "us", "we", or "Fund Manager"), an exempt reporting advisor for the venture fund Wisconn Valley Ventures, LP, respects your privacy and is committed to protecting personally identifiable information you may provide us. This Privacy Policy applies to information we collect through our website (e.g., http://wvvcapital.com) and other methods, including but not limited to emails, forms, surveys, meetings, investor communications, and other interactions (collectively, the "Services"). This Privacy Policy explains what information may be collected, how we use it, and under what circumstances we may disclose it to third parties. It does not apply to information collected from other sources unrelated to our Services.

This Privacy Policy, together with the Terms and Conditions posted on our website, sets forth the general rules and policies governing your use of our Services. Depending on your activities, you may be required to agree to additional terms and conditions.

Who We Are Fund Manager is the data controller for personal data collected under this Policy. Our contact details are: 1433 N. Water St. Suite 400, Milwaukee, WI 53202. For questions, rights exercises, or concerns, contact us at privacy@wvvcapital.com. For EU/EEA data subjects (as defined under GDPR), we process data in compliance with the General Data Protection Regulation (GDPR). If you are an EU/EEA resident, see the dedicated GDPR section below.

Information We Collect We collect information to provide our Services, manage investments, comply with legal obligations, and improve user experience. Categories include:

  • Non-personally identifying information: Browser type, language preference, referring site, date/time of each visitor request, and aggregated usage statistics (e.g., via cookies or similar technologies).

  • Personally identifying information: Name, email address, IP address, contact details, financial information (e.g., for investor onboarding), and other data you provide via forms, emails, or interactions.

  • Sensitive personal data: In limited cases, we may collect sensitive data (e.g., health/disability status, gender/sexual orientation, racial/ethnic origin, or biometric data) via email, forms, surveys, or other methods when required for government compliance, such as anti-money laundering (AML) checks under the Bank Secrecy Act, tax reporting (e.g., FATCA/CRS), diversity/EEO reporting, or other regulatory requirements. We only collect this where strictly necessary, notify you at the point of collection, and apply appropriate safeguards (e.g., minimization, access controls, and encryption where applicable).

We collect this information directly from you (e.g., when you submit a form, email us, or participate in a meeting) or automatically (e.g., via cookies, server logs, or analytics tools).

How We Use Your Information We use your information for:

  • Providing and improving our Services (e.g., responding to inquiries, managing investor relations).

  • Legal and regulatory compliance, including government requirements (e.g., KYC/AML verification, tax reporting, or filings where sensitive data is mandated).

  • Analytics and aggregated statistics (non-identifiable data only).

  • Security, fraud prevention, and operational purposes.

For sensitive personal data collected via email or other methods in connection with government requirements, we use it solely for that purpose (e.g., to fulfill legal obligations) and do not repurpose it without your explicit consent or another lawful basis.

Disclosure of Your Information We may disclose your information to:

  • Affiliates or service providers (e.g., for fund administration, under strict confidentiality agreements and data processing terms).

  • Government authorities or regulators when required by law (e.g., for compliance reporting).

  • In connection with legal proceedings (e.g., subpoenas or court orders).

We do not sell or share your personal information for marketing or advertising purposes without your consent.

Cookies and Tracking Technologies We use cookies and similar technologies to personalize content, track usage, store preferences, and enable functionality. You can refuse cookies via your browser settings, though some features may not work properly. By continuing to use our Services without changing your settings, you consent to our use of cookies.

Security We prioritize the security of your personal information using commercially acceptable means (e.g., encryption in transit and at rest where appropriate). However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security. We maintain physical, electronic, and procedural safeguards compliant with applicable laws, including federal standards for financial institutions.

Third-Party Services and External Links Our Services may use third-party services, tools, and technologies (such as analytics providers, hosting services, email platforms, cloud storage, or file-sharing tools) that collect, process, or store information about your interactions with our website or other Services. These third parties may set cookies, pixels, or similar tracking technologies on your device to enable functionality, measure usage, improve performance, or support operations.

Examples of such third-party services include Google, Dropbox, and Box. We only engage third parties that we believe provide adequate data protection safeguards, and we configure them (via settings and agreements) to handle your information in accordance with applicable privacy laws and our instructions.

We are not responsible for the privacy practices, data collection, or security measures of these third-party services. We encourage you to review their individual privacy policies for details on how they collect, use, share, and protect your information:

Additionally, our Services may contain links to external websites or resources operated by third parties that we do not control. Accessing or using such linked sites is at your own risk, and we are not responsible for their content, privacy policies, or data practices. We recommend reviewing the privacy policy of any third-party site you visit.

Aggregated Statistics We may collect and share aggregated, non-identifiable statistics about user behavior for informational or reporting purposes.

GDPR Compliance (for EU/EEA Data Subjects) If you are located in the EU/EEA, we process your personal data in accordance with the GDPR.

  • Lawful Bases for Processing: We rely on consent (where you provide it, e.g., for newsletters or optional communications), contract performance (e.g., investor agreements), legal obligations (e.g., regulatory compliance), or legitimate interests (e.g., site analytics, balanced against your rights). For sensitive/special category data, we rely on explicit consent, legal obligations (e.g., government requirements), or other Article 9 exceptions.

  • Collection: We collect only necessary data via our Services. For sensitive data collected via email/other methods for government compliance (e.g., AML/tax reporting), we notify you at collection and process it minimally.

  • Your Rights: You have the right to access, rectify, erase (where applicable), restrict processing, object, data portability, and withdraw consent at any time (without affecting prior lawful processing). To exercise these rights or withdraw consent, contact us at privacy@wvvcapital.com. We will respond within one month (extendable if complex). You may also lodge a complaint with your local supervisory authority.

  • International Transfers: Data may transfer to the US or other non-EEA countries; we use safeguards such as Standard Contractual Clauses or other approved mechanisms.

  • Retention: We retain data only as long as necessary for the purpose (e.g., legal retention periods for compliance data) or as required by law.

Privacy Policy Changes We may update this Policy at our discretion. Changes will be posted here—check periodically. Continued use after changes constitutes acceptance.

Credit & Contact Information Content is provided by CVC Manager, LLC, an exempt reporting advisor. Opinions are those of Fund Manager personnel and do not constitute tax, legal, or investment advice. Consult professionals for decisions. For questions, rights exercises, or concerns, contact us at privacy@wvvcapital.com.