Privacy Policy

Trace respects the privacy of visitors to our website located at (“Website”). This privacy policy (“Policy”) describes what personal data we collect from visitors to our Website (“you”, “your”), how and when this data is used, your choices in relation to your data and how you can contact us if you have questions about how we handle your data. If you are an investor or potential investor in a Trace fund entity or affiliated co-investment entity or a representative thereof, the privacy policy that governs the data that we collect about you in that context is separate from this Policy and is available by contacting us via the methods described below.

Data We Collect

When you interact with our Website, we may collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”), as described below.

Personal Data That You Provide: If you voluntarily submit information to us (for example, when you request information by completing our “Contact Us” form), we will collect your name, contact information (e.g., email and phone number), the content of your message or request and any other Personal Data that you elect to provide.

Automatically Collected Data: As you interact with our Website, our server collects certain usage information, such as information about the number and frequency of visitors, how users are directed to and visitor paths through our Website. We collect the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your internet protocol (“IP”) address.

Personal Data From Other Sources: We collect Personal Data from third parties in connection with your application for a job at Trace, including from referees, recruiters or recruitment platforms and organizations that provide background checks (this will include right to work, criminal, civil and regulatory reference checks, credit history, past work history, educational history, social media and professional licenses where applicable).

The Website also uses cookies to collect certain information about the usage of our Website to help us administer and improve the content, usability, and functionality of our Website, and to remember certain user attributes (for more information, please refer to the “Cookies” section below).

How We Use Personal Data

We use your Personal Data as necessary for certain legitimate business interests, which include the following:

  • To respond to your inquiries or questions;
  • To analyze Website usage through the use of cookies (described below) and provide, maintain and improve the content and functionality of the Website and your experience on it;
  • To administer our Website and prevent fraud, criminal activity, or misuses of our Website and ensure the security of our IT systems, architecture and networks;
  • To determine and validate your qualifications and suitability for employment, conduct background checks, communicate with you and if you are a successful applicant, to create an employment record; and
  • To comply with legal obligations, legal process, and procedures.

How We Share Data

We share, and have shared, the Personal Data outlined above as follows:

  • With our service providers who assist us in meeting business operations needs and to perform certain services and functions, including analytics (e.g., Google Analytics and WordPress), search engine providers, providers of hosting, cloud services and other information technology service providers that assist us in the maintenance, improvement and optimization of the Website;
  • With organizations that assist us with our recruitment processes, including recruitment agencies, professional bodies and educational establishments, background check providers and referees whose details you provide;
  • With any relevant third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, including in the event of a reorganization, dissolution, or liquidation; and
  • Any relevant party, claimant, law enforcement agency, court, governmental, supervisory, or regulatory bodies, to the extent necessary for the establishment, exercise or defense of legal rights in accordance with applicable law and regulation.

We do not sell Personal Data collected about you.


We use cookies in connection with the operation of the Website. By choosing to use the Website after having been notified of our use of cookies in the ways described in this Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

What Are Cookies. A “cookie” is a piece of information sent to your browser by a website you visit.

Type of Cookies Used. The Website uses the following technologies:

  • Strictly Necessary Cookies: On our investor portal on the Website, we use cookies set by Altvia Solutions, LLC, which are strictly necessary to provide users of the portal with access to it and to use some of their features, such as the ability to log-in or remember that a user is logged in, and access to secure areas. These cookies are essential for using and navigating the portal, therefore you cannot refuse them. Without these cookies, basic functions of the portal would not work.
  • Analytics: We use cookies for analytics purposes in order to better understand the behavior of the users on our Website and improve our Website accordingly, for example by making sure users are finding what they need easily. In particular, the Website uses:
    • Google Analytics. The information collected by Google (including your IP address) will be transmitted to and stored by Google, Inc. on servers in the United States. Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years.

Do Not Track. “Do Not Track” is a privacy preference that you can set in some web browsers, allowing you to opt out of tracking by websites and online services. Like many websites, our Website does not recognize or respond to Do Not Track requests.

International Data Transfers

We are based in the United States. Your Personal Data will be stored on servers in the United States. We will take steps to ensure that your information receives an adequate level of security protection where it is processed and your rights continue to be protected.

California Users

Scope. This section applies if you are a California resident visitor to our website.

Your Rights. Subject to applicable California law, including any exceptions, you may have the following rights in relation to your Personal Data:

  • Right to know: You may, not more than twice in a 12-month period, request more information about the Personal Data that we collect, use or disclose, and request a copy of such Personal Data.
  • Right to request deletion: You may request that we delete Personal Data that we have collected from you. However, we may not be required to delete your Personal Data under certain circumstances.

Right to non-discrimination: We will not discriminate against you for exercising your rights under the CCPA.

You may exercise your rights by contacting us as indicated under the “Contact Us” section below. To protect your Personal Data, we may need to verify your identity before processing your request to exercise your “right to know” and “right to request deletion.” In some cases, we may need to collect additional information to verify your identity, such as a government issued ID.  You may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.

Data Retention

We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Policy, while we have a legitimate business need to do so, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is the longer.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Linked Sites

This Website may contain links to other sites owned and operated by other parties. We are not responsible for and have no control over the privacy policies of those sites. By providing these links we do not imply that we endorse or have reviewed these sites. We encourage you to review the privacy policies of those sites prior to providing them with any information.

Changes to the Policy

We may change this Policy at any time. If we do so, we will post the updated version on our Website and notify you and follow such other steps as required by applicable law.

Contact Us

If you have any questions regarding our Policy or our privacy-related practices, please contact us here or at 713-217-2700.