Privacy Policy

Last Updated: November 1, 2025 | Effective Date: November 1, 2025

Sway for Future LLC ("Sway for Future," "we," "us," or "our") is committed to protecting your privacy and handling your personal information with transparency and care. This Privacy Policy explains how we collect, use, disclose, retain, and protect information about you when you visit our website at swayforfuture.com (the "Website"), communicate with us, apply for investment consideration, or otherwise interact with us. Please read this policy carefully. By using our Website or services, you acknowledge that you have read and understood this Privacy Policy.

1. Who We Are

Sway for Future LLC is a venture capital and impact investment firm headquartered at 535 Mission Street, Suite 1800, San Francisco, California 94105, United States. We operate as the Data Controller for personal information collected through our Website and investment operations, as defined under the European Union General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA/CPRA).

Our primary business activities include: evaluating and making seed-stage investments in technology companies; providing portfolio support and advisory services to invested companies; managing fund operations and investor relations; and publishing research and commentary on impact investing, technology sectors, and entrepreneurship.

We are registered as an investment adviser with the Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940. Our investment advisory activities are subject to separate regulatory requirements, including those relating to the handling of client and investor information.

2. Information We Collect

2.1 Information You Provide Directly

We collect personal information that you voluntarily provide to us through the following channels:

Founder and Startup Pitch Submissions: When you submit a pitch or application for investment consideration, we collect your name, email address, phone number, company name, company description, pitch deck contents (which may include financial projections, team information, and business plans), and any other information you choose to provide in your submission. We also collect information about your company, including but not limited to its legal structure, capitalization, technology, market positioning, and team composition.

Contact and Inquiry Forms: When you complete a contact form, inquiry form, or newsletter subscription form on our Website, we collect your name, email address, and any message content or other information you provide in the form fields.

Email and Other Direct Communications: When you communicate with us by email or other means, we collect the contact information you provide, the content of your communications, and any attachments you send. We retain copies of our correspondence with you as part of our business records.

Limited Partner and Investor Communications: If you are an existing or prospective limited partner in one of our investment funds, we collect information necessary to satisfy our regulatory obligations and fulfill our contractual commitments to you. This information may include your legal name and entity information, tax identification numbers, anti-money laundering verification information, accredited investor documentation, bank account information for capital calls and distributions, and investment preferences and objectives.

Event Registration: When you register for events, webinars, or programs hosted by Sway for Future, we collect your name, email address, organization, and any additional information required for the specific event.

2.2 Information Collected Automatically

When you visit our Website, we automatically collect certain technical information about your device and your use of the Website through cookies, web beacons, log files, and similar tracking technologies. This information includes:

• Internet Protocol (IP) address and approximate geographic location derived from IP address
• Browser type, version, and language settings
• Operating system and device type
• Pages visited, time spent on pages, and navigation paths through the Website
• Referring URLs (the website from which you arrived at our Website)
• Search terms used to find our Website
• Date and time of Website visits
• Cookie identifiers and web beacon data
• Links clicked within our Website

This automatically collected information is used for website analytics, security monitoring, performance optimization, and improving the user experience. It does not, on its own, identify you as an individual, but it may be combined with other information we hold about you.

2.3 Information from Third Parties

We may receive personal information about you from third parties in limited circumstances, including:

• Referrals from existing portfolio companies, investors, or partners who suggest that you connect with us
• Publicly available sources including company websites, LinkedIn profiles, press releases, regulatory filings, and news publications
• Background check and due diligence service providers, where we have a legitimate business reason to conduct such checks
• Analytics providers who supplement our Website analytics data with demographic and behavioral information
• Anti-money laundering and know-your-customer verification service providers

3. How We Use Your Information

3.1 Investment Evaluation and Operations

The primary purpose for which we collect information from founders and startup teams is to evaluate potential investment opportunities. We use this information to assess the quality and fit of investment opportunities, conduct due diligence on companies and founding teams, communicate with founders about the status of their applications, prepare investment documentation, and maintain our internal investment management systems and CRM. We retain pitch information for evaluation purposes and, if we make an investment, as part of our ongoing portfolio management records. If we do not make an investment, we may retain pitch information for a reasonable period to facilitate future communications.

3.2 Fund Management and Investor Relations

We use personal information collected from our limited partners and other fund stakeholders to administer our investment funds, process capital contributions and distributions, prepare and deliver required regulatory and tax documents, communicate about fund performance and portfolio developments, satisfy our anti-money laundering and know-your-customer obligations, and maintain accurate fund accounting records.

3.3 Website Operation and Improvement

We use automatically collected information and analytics data to understand how visitors use our Website, identify and fix technical errors, optimize website performance and user experience, develop new Website features and content, and monitor for security threats and unauthorized access. This use of data helps us ensure that our Website is functional, secure, and useful to our visitors.

3.4 Communications and Marketing

With your consent or where we have a legitimate interest in maintaining business relationships, we use your contact information to respond to inquiries and requests, send newsletters and updates about our investment activities and portfolio company news, invite you to events and programs, and provide other communications that we believe may be of interest to you based on your stated interests or relationship with us. You may opt out of marketing communications at any time by clicking the unsubscribe link in any marketing email or by contacting us at privacy@swayforfuture.com.

3.5 Legal and Compliance Obligations

We use and retain personal information as necessary to comply with our legal obligations as a registered investment adviser, including record-keeping requirements under the Investment Advisers Act of 1940 and SEC rules thereunder; anti-money laundering and know-your-customer requirements; tax reporting obligations; and any other applicable laws and regulations.

4. Legal Bases for Processing (GDPR)

For users in the European Economic Area, United Kingdom, or Switzerland, we process your personal information under the following legal bases as set forth in Article 6 of the GDPR:

Legitimate Interests (Article 6(1)(f)): We process personal information for our legitimate interests in evaluating investment opportunities, operating our business, maintaining business relationships, improving our Website and services, and communicating with people who have expressed interest in our work. When we rely on this basis, we have assessed that our interests do not override your fundamental rights and freedoms.

Contract Performance (Article 6(1)(b)): Where we have entered into a contractual relationship with you (for example, as a limited partner in one of our funds), we process your information as necessary to perform our obligations under that contract.

Compliance with Legal Obligations (Article 6(1)(c)): We process personal information as required by applicable laws and regulations, including our obligations as a registered investment adviser.

Consent (Article 6(1)(a)): Where we rely on your consent as a legal basis for processing (for example, for certain marketing communications), you have the right to withdraw that consent at any time by contacting privacy@swayforfuture.com. Withdrawal of consent does not affect the lawfulness of processing before the withdrawal.

Special Categories of Personal Data: We do not intentionally collect special categories of personal data (as defined under GDPR Article 9), such as health information, racial or ethnic origin, political opinions, or biometric data. If you voluntarily provide us with information that falls into a special category, we will handle it with appropriate safeguards as required by law.

5. Information Sharing and Disclosure

We do not sell your personal information to third parties for commercial purposes. We share personal information only in the following limited circumstances:

Service Providers: We engage third-party service providers who perform services on our behalf, including email delivery services, website hosting and analytics providers, CRM and deal management software providers, legal and accounting services, background check and due diligence providers, and document management services. These service providers are permitted to process your information only for the purposes for which they have been engaged and are required to maintain appropriate data security measures.

Co-Investors and Investment Partners: In the course of evaluating or pursuing investment opportunities, we may share founder and company information with co-investors, syndicate partners, or advisors who are directly involved in the evaluation or execution of a specific investment. We seek to obtain founder consent before sharing pitch materials with third parties in most circumstances.

Portfolio Company Information: As a board member or observer, we may receive and process information about portfolio companies that includes personal information about their employees, customers, and contractors. This information is handled as part of our portfolio management activities and is subject to confidentiality obligations.

Legal Requirements and Protection of Rights: We may disclose personal information if required to do so by law or in the good-faith belief that such disclosure is necessary to comply with legal process, respond to claims or legal proceedings, protect the rights, property, or safety of Sway for Future, our partners, our portfolio companies, or the public, or to enforce our agreements and policies.

Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or similar transaction affecting Sway for Future, personal information may be transferred as part of the transaction. We will provide notice of any such transfer to the extent required by law.

6. Cookies and Tracking Technologies

Our Website uses cookies and similar tracking technologies. For detailed information about the types of cookies we use, their purposes, and how to manage your cookie preferences, please review our Cookie Policy.

In summary, we use essential cookies necessary for the Website to function, analytics cookies that help us understand how visitors use the Website, and functionality cookies that remember your preferences. We do not use advertising or cross-site tracking cookies. You can control non-essential cookies through your browser settings or by using the cookie preference tools described in our Cookie Policy.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. The specific retention periods we apply are as follows:

Founder Pitch Materials: We retain pitch materials and related communications for a period of five years from the date of last meaningful contact. This retention period allows us to evaluate potential follow-on investment opportunities as companies evolve and to manage any legal disputes that may arise from the evaluation process. You may request deletion of your information earlier by contacting us at privacy@swayforfuture.com, and we will accommodate such requests unless we have a compelling legal reason to retain the data.

Website Analytics Data: Aggregated website analytics data is retained for two years. Raw log data is retained for 90 days.

Investment and Fund Records: Records related to our investment activities and fund management are retained for seven years following the end of the relevant fund's life, or for such longer period as may be required by applicable securities laws and regulations.

General Business Communications: Email and other general business communications are retained for three years from the date of the last communication, unless they relate to an ongoing legal matter or regulatory inquiry, in which case they are retained until the matter is resolved.

Legal Hold: We may extend retention periods when information is subject to a legal hold or litigation preservation requirement, regardless of the standard retention schedule.

8. Data Security

We implement technical, organizational, and physical security measures designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include encryption of data in transit using TLS/SSL protocols, access controls limiting personal data access to authorized personnel who need it for legitimate business purposes, regular security assessments and penetration testing, employee training on data handling and security practices, incident response procedures for detecting and responding to data breaches, and vendor security assessments for third parties who process personal data on our behalf.

No security system is impenetrable, and we cannot guarantee the absolute security of information transmitted over the internet or stored on our systems. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and applicable regulatory authorities as required by law, including within 72 hours of becoming aware of the breach where required under GDPR.

9. International Data Transfers

Sway for Future is headquartered in the United States. If you are located outside the United States, your personal information may be transferred to and processed in the United States, where data protection laws may differ from those in your jurisdiction.

For transfers of personal information from the European Economic Area, United Kingdom, or Switzerland to the United States, we rely on the following transfer mechanisms to ensure an adequate level of protection: Standard Contractual Clauses (SCCs) approved by the European Commission, where applicable; the EU-U.S. Data Privacy Framework or UK Extension thereto, where our service providers are certified participants; or other lawful transfer mechanisms as may be available under applicable law.

You may request a copy of the applicable transfer mechanism by contacting our Data Protection Officer at dpo@swayforfuture.com.

10. Your Rights Under GDPR

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the following rights with respect to your personal information, subject to certain limitations and exceptions under applicable law:

Right of Access (Article 15): You have the right to obtain confirmation of whether we process personal information about you, and to receive a copy of that information along with supplementary details about how it is processed.

Right to Rectification (Article 16): You have the right to request correction of inaccurate personal information and to have incomplete personal information completed.

Right to Erasure (Article 17): You have the right to request that we delete your personal information where there is no compelling reason for its continued processing, including where the information is no longer necessary for the purposes for which it was collected, you have withdrawn consent and there is no other legal basis for processing, or the information has been unlawfully processed.

Right to Restriction of Processing (Article 18): You have the right to request that we restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of the information or have objected to processing.

Right to Data Portability (Article 20): Where processing is based on consent or contract and carried out by automated means, you have the right to receive personal information you have provided to us in a structured, commonly used, machine-readable format, and to transmit that information to another controller.

Right to Object (Article 21): You have the right to object to processing of your personal information where it is based on legitimate interests, including for direct marketing purposes. Where you object to processing for direct marketing, we will cease that processing immediately. Where you object to other processing based on legitimate interests, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

Right Not to Be Subject to Automated Decision-Making (Article 22): You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects on you. We do not use fully automated decision-making processes that produce such effects.

Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at dpo@swayforfuture.com or our Privacy Team at privacy@swayforfuture.com. We will respond to all requests within one month, or within three months for complex or numerous requests (with notice of the extension provided within the initial one-month period). We may need to verify your identity before fulfilling certain requests.

If you are not satisfied with our response or believe we are processing your personal information unlawfully, you have the right to lodge a complaint with the supervisory authority in your country of residence. In the United States, the relevant authority is the Federal Trade Commission. In the EU, you may contact your national data protection authority.

11. Your Rights Under CCPA / CPRA

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) provides you with additional rights regarding your personal information:

Right to Know: You have the right to request that we disclose what personal information we have collected about you, the categories of personal information collected, the purposes for which the information is used, the categories of third parties with whom we share personal information, and the specific pieces of personal information we hold about you.

Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions including where the information is necessary to complete a transaction, detect security incidents, comply with legal obligations, or exercise free speech or other legal rights.

Right to Correct: You have the right to request correction of inaccurate personal information that we maintain about you.

Right to Opt-Out of Sale or Sharing: We do not sell personal information to third parties. We do not share personal information for cross-context behavioral advertising purposes. If this changes, we will provide a "Do Not Sell or Share My Personal Information" link on our Website and honor all opt-out requests.

Right to Limit Use of Sensitive Personal Information: We do not process sensitive personal information beyond the purposes permitted by the CPRA.

Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you goods or services, charge you different prices, provide a different level of service quality, or suggest that you will receive such treatment for exercising your privacy rights.

To exercise your CCPA/CPRA rights, please contact us at privacy@swayforfuture.com or call us at +1 (415) 847-3920. We will verify your identity using information you have previously provided to us or by asking you to confirm information we have on file. We will respond to verifiable consumer requests within 45 days, or within 90 days for complex requests (with notice provided within the initial 45-day period).

You may designate an authorized agent to make requests on your behalf. If you use an authorized agent, we may require written authorization from you and may contact you directly to verify your identity and the agent's authority.

12. Children's Privacy

Our Website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from anyone under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete that information as promptly as possible. If you believe we may have inadvertently collected information from a child, please contact us immediately at privacy@swayforfuture.com.

13. Third-Party Links and Services

Our Website may contain links to third-party websites, applications, and services. These third parties operate under their own privacy policies, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access through links on our Website before providing any personal information to those services.

We are not responsible for the content, privacy policies, or practices of any third-party websites or services, and we disclaim all liability for how third parties handle your personal information. The inclusion of a link on our Website does not imply endorsement of the linked website or service.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this policy, we will update the "Last Updated" date at the top of this document and, where required by law or where we believe it is appropriate given the nature of the change, we will notify you by email or by posting a prominent notice on our Website.

We encourage you to review this Privacy Policy periodically to stay informed about our data practices. Your continued use of our Website after any updates constitute your acceptance of the updated policy. If you do not agree with the updated policy, please discontinue use of our Website and contact us if you wish to exercise any applicable data rights.

15. Contact Information

For questions, concerns, or requests relating to this Privacy Policy or the handling of your personal information, please contact us through the following channels:

Privacy Team:
Email: privacy@swayforfuture.com
Mailing Address: Sway for Future LLC, Attn: Privacy Team, 535 Mission Street, Suite 1800, San Francisco, CA 94105, United States
Phone: +1 (415) 847-3920

Data Protection Officer (DPO):
Email: dpo@swayforfuture.com
This contact is specifically for GDPR-related inquiries from individuals in the European Economic Area, United Kingdom, or Switzerland.

European Union Representative:
Sway for Future has appointed an EU representative to handle data protection inquiries from EU residents. For EU-specific inquiries, you may contact us at eu-rep@swayforfuture.com in addition to contacting our DPO.

United Kingdom Representative:
For UK-specific data protection inquiries under the UK GDPR, please contact uk-rep@swayforfuture.com or write to our San Francisco office marked for the attention of our UK Privacy Representative.

We take all privacy inquiries seriously and will make every effort to respond promptly and helpfully. If you are not satisfied with our response to a privacy concern, you have the right to escalate your complaint to the relevant supervisory authority in your jurisdiction as described in Section 10 above.