CARAT Venture Partners (“CARAT Venture Partners” or “we” or “us”) is providing this website, www.caratvp.com, as an information service. By accessing www.caratvp.com and any of the memorandums, text, information, materials, or other content therein (the “Site”), clicking “I ACCEPT” upon registration on the Restricted Website (as defined below), and/or using the information, tools, content, and features located on it, you accept and agree to be bound by these terms of use agreement (“Terms”), as may be amended from time to time. You represent that (1) you have read, understand, and agree to be bound by these Terms, (2) you are of legal age to form a binding contract with us, and (3) you have the authority to enter the Terms personally or on behalf of the company you have named as the user and to bind that company to these Terms. The term “you” refers to the individual or legal entity, as applicable, identified as the user when you register on the Site. It is your responsibility to be aware of, and to comply with, these Terms and all applicable laws and regulations of any relevant jurisdiction when using the Site and related services. If you do not agree to be bound by these Terms, you may not access or use this Site.

ANY DISPUTE OR CLAIM RELATING IN ANY WAY TO YOUR USE OF THE SITE WILL BE GOVERNED AND INTERPRETED BY AND UNDER THE LAWS OF THE STATE OF DELAWARE, CONSISTENT WITH THE FEDERAL ARBITRATION ACT, WITHOUT GIVING EFFECT TO ANY PRINCIPLES THAT PROVIDE FOR THE APPLICATION OF THE LAW OF ANY OTHER JURISDICTION. THE UNITED NATIONS CONVENTION ON CONTRACTS FOR THE INTERNATIONAL SALE OF GOODS IS EXPRESSLY EXCLUDED FROM THIS AGREEMENT.

Please note that these Terms are subject to change by CARAT Venture Partners at its sole discretion at any time. When changes are made, we will make a new copy of the Terms available on the Site. We will also update the “Last Updated” date at the top of the Terms. PLEASE REGULARLY CHECK THE SITE TO VIEW THE THEN-CURRENT TERMS.

We may terminate, change, restrict, suspend, or discontinue any aspect of the Site, or your access to it, at any time without notice or liability to you.

Use of the Site

The Site, the Site Content (as defined below), and all other information and content available through the Site, are protected by copyright laws throughout the world.

You agree not to: (a) take any action that imposes an unreasonable load on this Site’s infrastructure; (b) use any device, software or routine to interfere or attempt to interfere with the proper working of this Site or any activity being conducted on this Site; (c) attempt to decipher, decompile, disassemble or reverse engineer any of the software comprising or making up this Site; (d) delete or alter any material posted on this Site by CARAT Venture Partners or any other person or entity; (e) frame or link to any of the materials or information available on this Site; (f) impersonate any person or entity or misrepresent your affiliation with any other person or entity, whether actual or fictitious, including anyone from this Site or CARAT Venture Partners; (g) obtain or attempt to gain unauthorized access to other computer systems, materials, information or any services available on or through this Site through any means, including through means not intentionally made publicly available or provided for through this Site; (h) engage in spidering, “screen scraping,” “database scraping,” harvesting of e-mail addresses or other personal information, or any other automatic or unauthorized means of accessing, logging-in or registering on this Site, or obtaining lists of users or other information from or through this Site including, without limitation, any information residing on any server or database connected to this Site; (i) use this Site or the content of this Site, including but not limited to the text and images herein and their arrangement, to violate, plagiarize or in any other manner infringe upon the rights of third parties, including without limitation, copyright, trademark, trade secret, confidentiality, contract, patent, rights of privacy or rights of publicity or any other proprietary or legal right; (j) upload, post, publish, distribute or otherwise transmit any information or material which constitutes or contains a virus, spyware, or other harmful component, or which contains any embedded links, advertising, chain letters or pyramid schemes of any kind; (k) disclose any sensitive, proprietary or confidential information, about yourself or anyone else, (l) attempt (or encourage or support anyone else’s attempt) to circumvent, reverse engineer, decrypt, or otherwise alter or interfere with this Site; or (m) use this Site or its services (or any Site Content (as defined below)), in whole or in part, or submit any information to this Site, in violation of any applicable law, rule or regulation.

Business Plans and Other Information Provided By You

We welcome unsolicited business plans. However, any information or materials that you consider trade secrets, confidential or proprietary should not be submitted to us. Absent an express written agreement to the contrary, any information or materials that you provide to us will not be considered confidential or proprietary and will not be returned or safeguarded. We reserve the right to turn down investment opportunities at our sole discretion. We receive many similar plans and ideas, and your idea may already have been submitted to us or be under consideration by us. We are not limited or restricted in any way from pursuing opportunities with others.

Our personal information collection, storage, and use policies with respect to this Site are set forth in our Privacy Policy, which is incorporated herein by reference for all purposes.

No Solicitation or Investment Advice

The purpose of this Site (including any portion of this Site available only to investors) is limited to providing you with general information on our services and philosophy. We do not render or offer to render investment advice through this Site. Nothing on this Site, including any investment memorandums, constitutes or forms a part of any offer for sale or subscription of, or any invitation to offer to buy or subscribe for, any securities or other financial instruments, nor should it or any part of it form the basis of or be relied upon in connection with, any contract or commitment whatsoever. We may only transact business or render investment advice in those jurisdictions where we are appropriately registered and/or licensed or where we are otherwise excluded or exempted from registration and/or licensing requirements. Any investments highlighted on this Site may have been selected for illustrative purposes in order to underscore the investment themes utilized by CARAT Venture Partners. The selected investments are not meant to imply the returns of any fund on an individual or aggregate basis. The information provided on the Site is illustrative and no assurance can be provided that any of the future events referenced herein will occur on the terms contemplated herein or at all. We do not speak on behalf of any company where information is highlighted for illustrative purposes. Any statistical information contained on the Site has been supplied for information purposes only and is not intended to be and does not constitute investment advice or an opinion regarding the appropriateness of an investment in any CARAT Venture Partners fund. There is no implication that any information contained on this Site, such as our investment memorandums, is accurate or that there has been no change in such information since the date first posted. Certain places on this Site may contain information created and published by institutions or organizations independent of us. We do not endorse, approve, certify, or control these materials. In addition, we do not guarantee or assume responsibility for the accuracy, completeness, efficacy, timeliness, or correct sequencing of information in any material on our website. Use of such information is voluntary, and reliance on it should be undertaken after an independent review of its accuracy, completeness, efficacy, and timeliness. Finally, reference in this Site to any specific commercial product, process, or service by trade name, trademark, service mark, manufacturer, or otherwise does not constitute or imply endorsement, recommendation, or favoring by us.

Forward-Looking Statements

The contents of the CARAT Venture Partners website may contain forward-looking statements that are based on beliefs, assumptions, current expectations, estimates, and projections about the financial industry, the economy, CARAT Venture Partners itself, or its investments. These statements are not guarantees of future performance and involve certain risks, uncertainties, and assumptions that are difficult to predict with regard to timing, extent, likelihood, and degree of occurrence, and may not prove to be correct. Therefore, actual results and outcomes may materially differ from what may be expressed or forecasted in such forward-looking statements. Furthermore, CARAT Venture Partners undertakes no obligation to update, amend or clarify forward-looking statements, whether because of new information, future events, or otherwise.

Third-Parties Sites

As a convenience to you, we may provide links from this Site to websites operated by other entities, including websites of our portfolio companies and websites that publish blogs, tweets, or other social media content written by CARAT Venture Partners’ personnel. You agree that it is impossible for CARAT Venture Partners to monitor such materials and that you access these materials at your own risk. We make no warranty or representation regarding any material or information on websites linked to or from this Site or any of the products or services described or offered for sale thereon, nor do we endorse or accept any responsibility for the information, material, products, or services offered on such websites. The content published in blogs written by our personnel does not necessarily represent our positions, strategies, or opinions, regardless of whether or not we provide links to these blogs on our Site. Links do not imply that any linked website is authorized to use any trademark, trade name, logo, or copyright symbol of CARAT Venture Partners or any of our affiliates.

CARAT Venture Partners Generated Content

The information and content posted on this Site (such as under “CARAT Venture Partners News,” “CARAT Venture Partners Blogs,” or elsewhere on the Site), is provided for informational and discussion purposes only and is not intended to be, and shall not be regarded or construed as, a recommendation for a transaction or investment or financial, tax, legal, or other advice of any kind. CARAT Venture Partners makes no warranty or representation regarding any such information or the data presented in such materials. In addition, it does not constitute or imply any commitment whatsoever, including without limitation an offer to purchase, sell or hold any security investment, loan, or other financial product or to enter into or arrange any type of transaction.

Intellectual Property

As between you and us, we own all rights, titles, and interest in and to this Site, all the content (including, without limitation, all text, audio, photographs, images, renderings, RSS feeds, podcasts, reports, memorandums, charts, logos, widgets, gadgets, applets, and video), software, code, data, and other materials thereon (collectively, the “Site Content”), the look and feel, design and organization of the Site, and the compilation of the Site Content. Your use of the Site does not grant to you ownership or title of, in, or to any Site Content or any other part of the Site.

Subject to these Terms, you may access, view, use, and display the Site and Site Content on your computer or other Internet-capable devices for your own, non-commercial purposes, provided that you comply fully with these Terms. You may not copy or display for redistribution to third parties any portion of the Site or the Site Content without the prior written permission of CARAT Venture Partners.

Copyright © 2022 CARAT Venture Partners. All rights reserved.

The trademarks associated with other companies that are published on our Site, including those of our portfolio and anti-portfolio, are owned by their respective owners. You are not permitted to use any trademarks, logos, service marks, and trade names (“Marks”) that are displayed on the Site without our prior written consent or the consent of such third party which may own the Marks.

Security

While we endeavor to protect the security and integrity of the information we may collect from you via the Site, as described in our Privacy Policy below, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. A third party could view the information you send in transit by electronic means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

Release

You hereby release and forever discharge CARAT Venture Partners (and our officers, employees, agents, successors, and assigns) from, and hereby waive and relinquish, each and every past, present and future dispute, claim, controversy, demand, right, obligation, liability, action and cause of action of every kind and nature (including personal injuries, death, and property damage), that has arisen or arises directly or indirectly out of, or that relates directly or indirectly to, the Site (including any interactions with, or act or omission of, other Site users or any Third-Party Sites). IF YOU ARE A CALIFORNIA RESIDENT, YOU HEREBY WAIVE CALIFORNIA CIVIL CODE SECTION 1542 IN CONNECTION WITH THE FOREGOING, WHICH STATES: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.”

Disclaimer

YOU EXPRESSLY UNDERSTAND AND AGREE THAT TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOUR USE OF THE SITE IS AT YOUR SOLE RISK, AND THE SITE AND SITE CONTENT ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITH ALL FAULTS. CARAT VENTURE PARTNERS EXPRESSLY DISCLAIMS ALL WARRANTIES, REPRESENTATIONS, AND CONDITIONS OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT ARISING FROM THE USE OF THE SITE.

YOU EXPRESSLY AGREE THAT YOUR USE OF THE SITE AND SITE CONTENT IS AT YOUR SOLE RISK. NEITHER WE NOR ANY OF OUR DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, OR CONTENT OR SERVICE PROVIDERS WARRANT THAT USE OF THE SITE WILL BE UNINTERRUPTED OR ERROR-FREE. THE SITE MAY BE SUBJECT TO DELAYS OR OTHER DISRUPTIONS. IN ADDITION, ALTHOUGH THE INFORMATION PROVIDED TO YOU ON THIS SITE IS OBTAINED OR COMPILED FROM SOURCES (INCLUDING, WITHOUT LIMITATION, INFORMATION FROM THIRD PARTIES) WE BELIEVE TO BE RELIABLE, NEITHER WE NOR ANY OF OUR DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, OR CONTENT OR SERVICE PROVIDERS MAKE ANY WARRANTY AS TO (I) THE RESULTS OR ANALYSIS THAT MAY BE OBTAINED FROM YOUR USE OF THE SITE OR SITE CONTENT, (II) THE ACCURACY, CURRENCY OR COMPLETENESS OF THE INFORMATION ON OUR SITE, OR (III) THE RELIABILITY OF ANY ADVICE, ANALYSIS, OPINION, STATEMENT OR OTHER MATERIALS DISPLAYED ON, OR DISTRIBUTED THROUGH, OUR SITE. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED FROM CARAT VENTURE PARTNERS OR THROUGH THE SITE WILL CREATE ANY WARRANTY NOT EXPRESSLY MADE HEREIN.

YOU ACKNOWLEDGE AND AGREE THAT CARAT VENTURE PARTNERS ARE NOT LIABLE, AND YOU AGREE NOT TO HOLD CARAT VENTURE PARTNERS LIABLE, FOR THE CONDUCT OF THIRD PARTIES, INCLUDING OPERATORS OF EXTERNAL SITES THAT ARE LINKED TO THE SITE, AND THAT THE RISK OF INJURY FROM SUCH PARTIES RESTS ENTIRETY WITH YOU. YOU ARE SOLELY RESPONSIBLE FOR ALL OF YOUR COMMUNICATIONS AND INTERACTIONS WITH OTHER USERS OF THE SITE. YOU UNDERSTAND THAT CARAT VENTURE PARTNERS DO NOT MAKE ANY ATTEMPT TO VERIFY THE STATEMENTS OF USERS OF THE SITE.

International Use

Due to the global nature of the Internet, this Site may be accessed by users in countries other than the United States. We make no warranties that materials on this website are appropriate or available for use in such locations. If it is illegal or prohibited in your country of origin to access or use this Site, then you should not do so. Those who choose to access this Site outside the United States do so on their own initiative and are responsible for compliance with all local laws and regulations.

Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAWS, IN NO EVENT, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE, SHALL WE, OR ANY OF OUR DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, OR CONTENT OR SERVICE PROVIDERS (COLLECTIVELY, THE “PROTECTED ENTITIES”) BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY OR PUNITIVE DAMAGES ARISING FROM, OR DIRECTLY OR INDIRECTLY RELATED TO: (1) THE USE OR INABILITY TO USE THE SITE, MATERIALS OR SERVICES; (2) THE COST OF PROCUREMENT OF SUBSTITUTE MATERIALS, GOODS OR SERVICES RESULTING FROM ANY GOODS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED FOR TRANSACTIONS ENTERED INTO THROUGH THE SITE; (3) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (4) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SITE; OR (5) ANY OTHER MATTER RELATED TO THE SITE, WHETHER BASED ON WARRANTY, COPYRIGHT, CONTRACT, TORT (INCLUDING NEGLIGENCE), PRODUCT LIABILITY OR ANY OTHER LEGAL THEORY, EVEN IF SUCH PROTECTED ENTITY HAS BEEN SPECIFICALLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IF YOU ARE DISSATISFIED WITH THIS SITE, ANY MATERIALS OR SERVICES ON THIS SITE, OR WITH ANY OF THE TERMS, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE SITE.

Restricted Websites

The Site may provide a link or connect you directly to a password-protected third-party website designed specifically to provide investors with certain information (the “Restricted Website”). Your use of the Restricted Website is governed by these Terms. The information contained in the Restricted Website is confidential and is subject to the confidentiality provisions contained in the relevant partnership agreements of private investment funds managed by CARAT Venture Partners (such funds, the “CARAT Partners Funds”). As a limited partner of one or more of the CARAT Partners Funds, or a representative of such a limited partner, you are subject to those confidentiality provisions. By use of the Restricted Website, you agree that the information relating to CARAT Partners Funds in which you are not a limited partner is subject to the same confidentiality restrictions that apply to you as a limited partner in any of the CARAT Partners Funds. The information contained in the website may not be reproduced or redistributed in any manner unless expressly permitted by the partnership agreement of the applicable CARAT Partners Fund or as otherwise agreed to by CARAT Venture Partners. You are responsible for all activity occurring when the Restricted Website is accessed through your account, whether authorized by you or not. Therefore, be sure to protect the confidentiality of your account password. We are not liable for any loss or damage arising from your failure to protect your password or account information. The information contained in the Restricted Website may include material non-public information regarding the CARAT Partners Funds and their underlying portfolio companies. It is a violation of U.S. securities laws for a person in possession of material non-public information concerning an issuer to purchase or sell securities of such issuer or to communicate such information to another person under circumstances in which it is reasonably foreseeable that such person is likely to purchase or sell securities.

Electronic Communications

The communications between you and CARAT Venture Partners use electronic means, whether you visit the Site or send CARAT Venture Partners e-mails, or whether CARAT Venture Partners posts notices on its properties or communicates with you via e-mail. For contractual purposes, you (1) consent to receive communications from CARAT Venture Partners in an electronic form; and (2) agree that all terms and conditions, agreements, notices, disclosures, and other communications that CARAT Venture Partners provides to you electronically satisfy any legal requirement that such communications would satisfy if it were to be in writing. The foregoing does not affect your statutory rights.

Exclusive Venue

To the extent, the parties are permitted under this Agreement to initiate litigation in a court, both you and CARAT Venture Partners agree that all claims and disputes arising out of or relating to the Agreement will be litigated exclusively in the state or federal courts located in Delaware.

Governing Law

THE TERMS AND ANY ACTION RELATED THERETO WILL BE GOVERNED AND INTERPRETED BY AND UNDER THE LAWS OF THE STATE OF DELAWARE, CONSISTENT WITH THE FEDERAL ARBITRATION ACT, WITHOUT GIVING EFFECT TO ANY PRINCIPLES THAT PROVIDE FOR THE APPLICATION OF THE LAW OF ANOTHER JURISDICTION. THE UNITED NATIONS CONVENTION ON CONTRACTS FOR THE INTERNATIONAL SALE OF GOODS DOES NOT APPLY TO THE AGREEMENT.

Miscellaneous

These Terms and our relationship with you shall be governed by the laws of the State of Delaware, without regard to its conflict of law provisions. Our failure to exercise or enforce any right or provision of these Terms shall not constitute a waiver of such right or provision. If any provision of these Terms is found to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties’ intentions as reflected in that provision and the other provisions of these Terms remain in full force and effect. The Terms are the final, complete, and exclusive agreement of the parties with respect to the subject matter hereof and supersedes and merge all prior discussions between the parties with respect to such subject matter.

Questions

If you have any questions, complaints, or claims, relating to the Site, please contact us at info@caratvp.com. We will do our best to address your concerns.

Effective Date November 29, 2022

Privacy Policy

Last revised on: November 29, 2022

CARAT Venture Partners believes that personal privacy is a core civil liberty. We also believe that transparency in our policies and practices builds trust with our investors, portfolio companies, and partners. Although a certain amount of legalese in this policy is unavoidable, we have done our best to plant a flag in the ground on privacy and institute policies and procedures to back it up. This Privacy Policy explains the types of information we collect through www.caratvp.com (the “Site”) and how we will use, disclose and plan to protect such information once it is collected. As our firm and the venture capital industry evolve, this Privacy Policy may change, so please check this page periodically to ensure you are up to date with our current practices. By using or accessing our Services in any manner, you acknowledge the practices and policies regarding our collect, use, and share your information as described in this Privacy Policy.

The Site is owned and operated by CARAT Venture Partners and its affiliates (referred to collectively in this Privacy Policy as “we,” “us,” “our” and other similar pronouns).

1. What information do we collect on the Site?

We collect the following categories of personal information from or about Site users concerning the use of the Site.

Category of Personal Information

Examples of Personal Information We Collect

Categories of Third Parties With Whom We Share this Personal Information:

Profile or Contact Data

• First and last name
• Email
• Phone number
• Company name
• Title

• Service Providers
•Business Partners
• Parties You Authorize, Access, or Authenticate

Device/IP Data

• IP address
• Device ID
• Domain server
• Type of device/operating system/browser used to access the Site

• Service Providers
• Business Partners
• Parties You Authorize, Access, or Authenticate

Web Analytics

• Web page interactions
• Referring webpage/source through which you accessed the Site
• Non-identifiable request IDs
• Statistics associated with the interaction between the device or browser and the Site

• Service Providers
• Business Partners
• Parties You Authorize, Access, or Authenticate

Other Identifying Information that You Voluntarily Choose to Provide

• Identifying information in emails or letters you send us

• Service Providers
• Business Partners
• Parties You Authorize, Access, or Authenticate

We collect Personal Information about you from the following categories of sources:

• You

  • When you provide such information directly to us.

    • When you use our Site.

    • When you voluntarily provide information in free-form text boxes through the Site or through responses to surveys or questionnaires.

    • When you send us an email or otherwise contact us.

  • When you use the Site and such information is collected automatically.

    • Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).

• Third Parties

  • Vendors

    • We may use analytics providers to analyze how you interact and engage with the Site, or third parties may help us provide you with customer support.

2. How do we use your information?

Our Commercial or Business Purposes for Collecting Personal Information

• Providing, Customizing, and Improving the Site

  • Providing you with the products, services, or information you request.

  • Meeting or fulfilling the reason you provided the information to us.

  • Providing support and assistance for the Site.

  • Improving the Site, including testing, research, internal analytics, and product development.

  • Personalizing the Site, website content, and communications based on your preferences.

  • Doing fraud protection, security, and debugging.

  • Carrying out other business purposes stated when collecting your Personal Information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

• Corresponding with You

  • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about us or the Site.

  • Sending emails and other communications according to your preferences or that display content that we think will interest you.

• Meeting Legal Requirements and Enforcing Legal Terms

*

• Fulfilling our legal obligations under applicable law, regulation, court order, or other legal processes, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.

• Protecting the rights, property, or safety of you, us, or another party.

• Enforcing any agreements with you.

• Responding to claims that any posting or other content violates third-party rights.

• Resolving disputes.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

3. Sharing with Third Parties

We generally do not share information collected about you through the Site.

We may, however, share your information (i) with third parties who provide services to us (such as hosting, technology and communication providers, and analytics providers), (ii) as required by law and when we believe in good faith that disclosure is necessary to protect our rights or those of third parties, protect your safety or the safety of others, investigate fraud, or comply with a court order or other legal process, (iii) among our affiliates for our business purposes in accordance with this Privacy Policy, or (iv) in connection with a corporate change or dissolution, including a merger, acquisition, sale of assets, reorganization, consolidation, bankruptcy, liquidation or wind down of business.

In addition, we may share non-personally identifiable Site usage information (including aggregated and de-identified data) with others, for their own use, in a form that does not include your name or contact information. The third parties that support our website analytics tools may be able to access and use your Site usage information.

4. Social Media and Links to Third-Party Websites

We maintain a presence on several social media platforms, such as Twitter, Medium, and LinkedIn, and we also incorporate some third-party social media features onto the Site. We also include tools on the Site that allow you to share and/or publicly post content or information from the Site to your profile on a third-party social media platform. Third-party social media platforms have their own privacy policies which explain how they will use, protect and share your information, including any information you share on those platforms from the Site, and we encourage you to read them. As described in our Cookie Policy, our Site may incorporate third-party cookies from social media platforms, which you have management rights over.

Our Site may also contain links, banners, widgets, or advertisements that lead to other websites, including investor portals, personal blogs, tweets, and other social media content written or edited by members of our staff, and these sites or entities may collect your Personal Information. We have no control over, do not review, and are not responsible for these other sites or their content, so their privacy policies (not this Privacy Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of such websites to understand how your information is treated. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

Information that you may provide, or that we may obtain, through your access to password-protected websites, such as an investor portal, that you may be able to access by following a hyperlink on the Site (each such other website, an “Access-Restricted Website”), is subject to the privacy policies and practices of the operators of the Access-Restricted Website available on such Access-Restricted Website, which we encourage you to read to learn about the treatment of such information.

5. Your Access Rights

If you have an account hosted through an Access-Restricted Website, please refer to the privacy policies and practices of the operators of the Access-Restricted Website available on such Access-Restricted Website to understand your rights to review, update or modify certain of the information that is stored in that account.

6. Tracking Tools and Opt Out

We and our service providers may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Site, analyze trends, learn about our user base and operate and improve our Site. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to access our Site. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies, as further described in our Cookie Policy.

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site. Disabling these Cookies may make certain features and services unavailable.

• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Site, maintain your preferences over time and recognize you when you return to our Site. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

• Performance/Analytical Cookies allow us to understand how visitors use our Site. They do this by collecting information about the number of visitors to our Site, what pages visitors view on our Site, and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Site content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/

• Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.

Information on how to opt-out of non-essential cookies can be found in our Cookie Policy.

Please note that some web browsers may transmit “do-not-track” (“DNT”) signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.

7. Privacy Rights of California Residents.

If you are a resident of California, you have the rights set forth in this section. If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Information shall control the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at info@caratvp.com.

Access

You have the right to request certain information about our collection and use of your Personal Information over the past 12 months, including the:

• Categories of Personal Information that we have collected about you.

• Specific pieces of Personal Information that we have collected about you.

• Categories of sources from which that Personal Information was collected.

• Business or commercial purpose for collecting your Personal Information.

• Categories of third parties with whom we have shared your Personal Information.

• Categories of Personal Information shared with third parties for a business purpose over the past 12 months, if applicable.

Deletion

You have the right to request that we delete the Personal Information that we have collected about you, subject to certain exceptions under the CCPA: for example, we may need to retain your Personal Information to provide you with the Site or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your CCPA Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Information or are an agent authorized by that person and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You may submit a Valid Request pursuant to the following method:

• Email us at: pinfo@caratvp.com

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

We Do Not Sell Your Personal Information

We will not “sell” your Personal Information, as that term is defined in the CCPA, and have not done so over the last 12 months. We also do not sell the Personal Information of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not deny you access to our Site or provide you with a lower quality of services if you exercise your rights under the CCPA. If you have any questions about this section or whether any of the above rights apply to you, please contact us at info@caratvp.com.

8. Privacy Rights of Other United States Residents

California Resident Rights

California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes, under California Civil Code Sections 1798.83-1798.84. If you would like to submit such a request, please contact us at info@caratvp.com.

9. Privacy Rights of Certain European Residents

The Site is hosted and operated in the United States (“U.S.”) by us and through our service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (“GDPR”) with respect to your Personal Information, as outlined below. By using the Site, you acknowledge that any Personal Information about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the U.S. and will be hosted on U.S. servers, and you authorize us to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.

For this section, we use the terms “Personal Information” and “processing” as they are defined in the GDPR, but “Personal Information” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage, and disclosure. We will be the controller of your Personal Information processed in connection with your use of the Site.

If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at info@caratvp.com.

Personal Information Collection, Use, and Disclosure

The “Categories of Personal Information We Collect” subsection of this Privacy Policy above details the Personal Information that we collect from you, and “How We Share Your Personal Information” details how we may use or disclose your Personal Information.

Legal Basis for Processing

We will only process your Personal Information if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We may process Personal Information as a matter of “contractual necessity”, meaning that we may need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Site. When we process data due to contractual necessity, failure to provide such Personal Information will result in your inability to use some or all portions of the Site that require such data.

• Legitimate Interest: We process the following categories of Personal Information when we have a legitimate interest that is not outweighed by your privacy rights:·        

• Device/IP Data

• Web Analytics

• Other Identifying Information You Choose to Provide

• We may also de-identify or anonymize Personal Information to further our legitimate interests.

• Consent: In some cases, we process Personal Information based on the consent you expressly grant to us at the time we collect such data. When we process Personal Information based on your consent, it will be expressly indicated to you at the point and time of collection.

EU Data Subject Rights

You have certain rights with respect to your Personal Information, including those set forth below.

• Access: You can request more information about the Personal Information we hold about you and request a copy of such Personal Information.

• Rectification: If you believe that any Personal Information we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.

• Erasure: You can request that we erase some or all of your Personal Information from our systems.

• Withdrawal of Consent: If we are processing your Personal Information based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time.

• Portability: You can ask for a copy of your Personal Information in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Information for certain purposes, such as for direct marketing purposes.

• Restriction of Processing: You can ask us to restrict further processing of your Personal Information.

• Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Information with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

For more information about these rights, or to submit a request, please contact us at info@caratvp.com

Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Information, if necessary to verify your identity and the nature of your request.

10. Security and Retention

We seek to protect your Personal Information from unauthorized access, use, and disclosure using appropriate physical, technical, and administrative security measures and storage and processing practices based on the type of Personal Information. We retain Personal Information about you for as long as necessary to provide our Site, comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law, rule, or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data or storing data over the Internet is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

11. A Note About Children

We do not intentionally gather personal information from visitors who are under the age of 13. If a child under 13 submits personal information to us and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at info@caratvp.com.

12. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When we do, we will let you know by posting the changed Privacy Policy on this page. In some cases, for example, if we make any significant changes, we may tell you about changes by additional means, such as by sending you an e-mail. In some cases, we may request your consent to the changes. Any changes will be effective immediately upon posting to the Site.

13. Contact Us

We welcome your questions and comments about privacy. Please feel free to contact us by sending an e-mail to info@caratvp.com.

CARAT Venture Partners Cookie Policy

Last updated: November 29, 2022

CARAT Venture Partners and its affiliates (referred to in this Cookie Policy as “we,” “us,” or “our”) and our partners use Cookies or similar technologies to gather and analyze information about you and how you use our Site. We put together this Cookie Policy to provide you with more information about these Cookies and technologies.

I. ABOUT COOKIES

The Site uses Cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript to enable our servers to recognize your web browser and tell us how and when you visit and use our Site, to analyze trends, learn about our user base and operate and improve our Site. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device, when you use that device to visit a Site. We will refer to Cookies and similar technologies simply as “Cookies” for the remainder of this Cookie Policy. We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are or whether you have an account with us. We may also supplement the information we collect from you with information received from third parties. For more information about the kinds of Cookies we use and the purposes for which we use Cookies, please consult the chart below.

II. TYPES OF COOKIES WE USE

The table below explains what Cookies are used on the Websites.

Types of cookie

Who serves these Cookies

How to refuse

Essential Website Cookies: These Cookies are strictly necessary to provide you with services available through our Websites and to use some of its features, such as access to secure areas.

CARAT Venture Partners (www.caratvp.com)

Because these Cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. You can block or delete them by changing your browser settings, however, as described below.

Performance and functionality Cookies: These Cookies are used to enhance the performance and functionality of our Websites but are non-essential to their use. However, without these Cookies, certain functionality may become unavailable.

Spotify (www.spotify.com)

To refuse these Cookies, use our Consent Management Tool or follow the instructions below under the heading “How can I control Cookies?”

Analytics and customization Cookies: These Cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or to help us customize our Websites for you.

Google Analytics (analytics.google.com)

To refuse these Cookies, use our Consent Management Tool or follow the instructions below under the heading “How can I control Cookies?”

Alternatively, please click on the relevant opt-out link below: Google Analytics

Advertising Cookies: These Cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests.

Google AdSense (www.google.com), YouTube (youtube.com), DoubleClick (doubleclick.net)

To refuse these Cookies, use our Consent Management Tool or follow the instructions below under the heading “How can I control Cookies?”

Alternatively, please click on the relevant opt-out link below: Google Ads

Social networking Cookies: These Cookies are used to enable you to share pages and content that you find interesting on our Websites through third-party social networking and other websites. These Cookies may also be used for advertising purposes too.

Facebook (www.facebook.com), LinkedIn (www.linkedin.com), Twitter (www.twitter.com)

To refuse these Cookies, use our Consent Management Tool or follow the instructions below under the heading “How can I control Cookies?”

Alternatively, please click on the relevant opt-out link below: Facebook, Google Social, LinkedIn, Twitter

III. COOKIE SETTINGS

You have the right to decide whether to accept or reject Cookies. You can exercise your cookie preferences by using our Consent Management Tool or by clicking on the appropriate opt-out links provided in the cookie table above.

You can also set or amend your web browser controls to accept or refuse Cookies. If you choose to reject Cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse Cookies through your web browser controls vary from browser to browser, you should visit your browser’s help menu for more information. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutCookies.org/.

Freedom from Harassment, Discrimination, and Retaliation Policy

Policy Statement

It is the policy of CARAT Venture Partners (the “Company”) to provide and maintain a work environment for its personnel and third parties with whom its personnel interacts that is free of discrimination and harassment, including sexual harassment. The Company prohibits harassing and/or discriminatory conduct in the workplace, whether based upon race, sex, color, age, national origin, religion, disability, genetic information or predisposition, sexual orientation, gender identity and/or expression, ancestry, marital, veteran or citizenship status or any other basis prohibited by applicable laws. This policy applies to all terms and conditions of employment or other engagement of personnel with the Company, including, but not limited to, hiring, placement, promotion, termination, layoff, recall, transfer, leave of absence, compensation and training, and to interactions among Company personnel and between Third Parties (as defined below) and Company personnel or other Third Parties in connection with conducting business or proposed business involving the Company (“Third Party Company Interactions”).

Sexual Harassment

The Company prohibits sexual harassment, which includes sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature that has the purpose or effect of interfering with an employee’s work performance by creating an intimidating, hostile, humiliating, or sexually offensive working environment. Personnel may not threaten or insinuate, either explicitly or implicitly, that submission to or rejection of sexual advances, sexual favors, or other conduct of a sexual nature will in any way influence or adversely affect any decision by the Company regarding an individual’s hiring or employment, including, but not limited to, evaluation, wages, advancement, assigned duties, shifts, or any other condition of employment or career development. Further, no Company personnel may engage in any conduct that creates an intimidating, hostile, or offensive work environment. While it is not possible to list all of the circumstances and conduct that may constitute sexual harassment, the following are some examples of conduct that, if unwelcome, may constitute sexual harassment depending upon the totality of the circumstances, including the severity of the conduct and its pervasiveness:

• Unwelcome sexual advances or requests for sexual favors, sexual language, sexual jokes, innuendo, and/or comments about an individual’s body;

• Submission to such conduct is made either explicitly or implicitly a term or condition of employment;

• Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting the individual; or

• Such conduct has the purpose or effect of unreasonably creating an intimidating, hostile, or offensive working environment.

It is important to note that this policy is not intended to limit the Company’s authority to discipline or take remedial action for conduct that we regard as unacceptable inside or outside of the workplace or otherwise involving work activities, regardless of whether that conduct meets the legal definition of sexual harassment.

Determinations of whether a particular language or conduct is subject to disciplinary action under this policy will be made on a fact-specific basis, in light of all of the circumstances. The following, however, are some additional examples of conduct that all personnel of the Company must avoid. Such conduct may violate the Company’s policy against sexual harassment, whether or not it constitutes sexual harassment under the law.

This is not an exhaustive list:

• Comments to, or about, an individual’s appearance that are sexually graphic or would otherwise tend to be degrading;

• Inappropriate touching and/or physical contact of a sexual nature;

• Sexual gestures or remarks with sexual content that are graphic or that may otherwise be offensive to others;

• Repetition of any words or conduct of a sexual nature after the person addressed has indicated that such words or conduct is unwelcome;

• Unwelcome sexual advances or propositions, whether or not involving physical touching;

• Sexual epithets, jokes, written or oral references to sexual conduct, gossip concerning one’s sex life, comment on an individual’s body or sexual activity;

• Displaying or circulating sexually suggestive objects, pictures, or other images, including by e-mail;

• Requests for sexual favors; and

All other verbal or physical conduct of a sexual or otherwise offensive nature.

Sex-based harassment — that is, harassment not involving sexual activity or language (e.g., male manager yells only at female personnel and not males) — may also constitute discrimination if it is severe or pervasive and directed at personnel because of their sex.

The Company’s anti-harassment policy applies to all Company personnel (including for the avoidance of doubt, all Company employees, consultants, and others involved in the operations of the Company) and all Third Parties in Third Party Company Interactions. The policy prohibits harassment by (a) Company personnel of other Company personnel and, during Third Party Company Interactions, of Third Parties (as defined below) and (b) Third Parties of Company personnel and, during Third Party Interactions, of other Third Parties. While the Company may not have direct control over a portfolio company or prospective portfolio company personnel or other industry participants in which Company personnel may interact, including, without limitation, entrepreneurs, contractors, fund investors, and other industry investors, vendors, clients, and volunteers (including in all cases prospective relationships) (collectively referred to as “Third Parties” or a “Third Party”), the Company is committed to a policy of influencing Third Parties to act consistently with the Company’s anti-harassment policy, both as applied to prohibit harassment of Company personnel but also harassment of other Third Parties. If harassment occurs by a Third Party in violation of this policy, the reporting procedures in this policy should be followed as if the harasser were Company personnel.

For the avoidance of doubt, references to employees in this policy shall be broadly interpreted to include all Company personnel.

Harassment on the Basis of Any Other Protected Characteristic

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his/her race, color, religion, national origin, age, disability, pregnancy, alienage or citizenship status, marital status, creed, genetic information or predisposition, sexual orientation, gender identity and/or expression, ancestry, veteran status or any other characteristic protected by applicable laws or that of his/her relatives, friends or associates, and that: (i) has the purpose or effect of creating an intimidating, hostile or offensive work environment; (ii) has the purpose or effect of interfering with an individual’s work performance; or (iii) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes, but is not limited to: epithets, slurs, or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes and display or circulation in the workplace of written or graphic material that denigrates or shows hostility or aversion toward an individual or group (including through E-mail).

Conduct that is prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as business trips and/or business-related social events. These policies apply to all Company personnel and prohibit harassment, discrimination and/or retaliation whether engaged in with respect to or by fellow personnel, a supervisor or manager, or Third Parties.

Retaliation is Prohibited

It is also a violation of this policy and is unlawful to retaliate against any individual for making or filing a complaint of discrimination and/or harassment either internally or with a government agency, for opposing harassment or discrimination, for cooperating in an internal and/or governmental investigation of a complaint of discrimination or harassment, or for participating in a hearing or other proceeding related to a claim of discrimination or harassment. Any such retaliation will result in disciplinary action, up to and including termination of employment.

Complaint Procedure

​1.​ Complaint Procedure

The Company takes allegations of discrimination, harassment (including sexual harassment), and retaliation very seriously and will respond promptly to any complaints. When the Company determines that such conduct has occurred, the Company will act to eliminate the discrimination, harassment, and/or retaliation and impose such disciplinary action as it deems necessary, up to and including termination.

Any Company personnel or Third Party who believes he or she or anyone else at the Company or any Third Party has been subjected to or affected by any such harassing and/or discriminatory conduct in violation of this policy, whether by a supervisor, a co-worker or any other person with whom the individual comes in contact in connection with during his or her work for the Company or otherwise in connection with conducting business or proposed business involving the Company, is expected to report such conduct immediately. Reports should be made immediately to the Company’s General Counsel or Chief Financial Officer. Alternatively, Company personnel may report such conduct to one of the Company’s Managing Partners. If a Managing Partner receives a report, or a Managing Partner or any other Company personnel in a supervisory capacity is otherwise aware of harassing, discriminatory, and/or retaliatory conduct, the Managing Partner or such supervisor is required to advise Carat Venture Partners General Counselor or Chief Financial Officer of any such conduct. The Company’s General Counsel and Chief Financial Officer can be reached via electronic email at info@caratvp.com.

All complaints will be investigated thoroughly, promptly, impartially, and with discretion. All information obtained from the investigation will be handled discreetly and communicated on a “need to know” basis consistent with adequate investigation and appropriate corrective action. The investigation may include (but will not necessarily be limited to) interviews with the individual who made the complaint, with the person or persons against whom the complaint was made, and with individuals who may have witnessed the reported incident or incidents. In addition, personnel should be aware that in certain cases, information must be shared in order for an effective investigation to be conducted.

At the conclusion of an investigation, appropriate, remedial, and/or disciplinary action will be taken. The individual reporting harassing or discriminatory behavior under this complaint procedure will be advised of the Company’s decision(s) at the conclusion of the investigation.

In order to allow the Company to prevent and correct unlawful harassing, discriminatory, and/or retaliatory conduct, it is essential that personnel or Third Parties use this Complaint Procedure and that the Company receives the information about instances of such conduct immediately after the conduct. The Company will not tolerate any retaliation and/or intimidation as a result of using this Complaint Procedure.​

​2.​ Other Remedies and Appropriate Agencies

In addition to the complaint process described above, any individual who believes he or she has been subjected to or affected by any harassing and/or discriminatory conduct may file a formal complaint with the appropriate governmental agencies and/or may commence an appropriate lawsuit as permitted by applicable law.

Disciplinary Actions

Violations of the Company’s Equal Employment Opportunity (“EEO”) and Freedom from Harassment and Anti-Discrimination policies and/or misconduct constituting harassment, discrimination or retaliation will be dealt with promptly and appropriately. Responsive action will be based upon the specific circumstances of the offense and may include discipline up to and including termination of employment. Additionally, in certain cases, individuals may also be held both criminally and financially liable.