Privacy Policy 2020-01-08T14:52:25+00:00

Privacy Policy

Thank you (“you” or “user”) for visiting the website of Rubicon Technology Management L.L.C. and its affiliates (together, “Rubicon”, “we” or “us”).  Your visit to this website (the “Site”) is subject to this Privacy Policy.  By visiting the Site, you agree to this Privacy Policy, which may be updated by us at any time.  If we update our Privacy Policy, we will post the updated document here.  Any such changes will be effective upon posting.  We urge you to review the Privacy Policy each time you visit the Site.  If you do not agree with any provision of the Privacy Policy, you should not visit or use the Site.

This Privacy Policy does not concern your interaction with Rubicon in any manner other than your use of the Site.  This Privacy Policy also does not address our privacy practices with respect to any nonpublic personal information we may collect from you as an investor in investment vehicles managed or advised by Rubicon.  We address these practices in separate notices to investors or potential investors.

Your privacy is important to us.  This Privacy Policy seeks to help you understand whether and how we collect information about you when you visit the Site, and how we use such information. 

If you have any questions or comments about our Privacy Policy, you can email us at or write to us at Rubicon Technology Management L.L.C., 1911 11th Street, Suite 400, Boulder, CO 80302, Attn. Jon Franke.

What Information We Collect

This Privacy Policy applies to information collected from, or which may be submitted to, the Rubicon Site. At the present time, we do not collect any personally identifiable information about visitors to the publicly available areas of our Site, including any visitors’ names, addresses, phone numbers, social security numbers or email addresses. At times, visitors to our Site may choose to email individuals at Rubicon using links available on our site; in such instances, a visitor’s name, email address, and other contact information may be collected as part of the process of sending the email to us in order to enable us to reply to those emails. We may monitor and record other activity on our Site for any reason or for no reason.

We may collect information about you through technology.  For example, we may collect your IP address each time you request a page during a visit to the Site.  At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site.  The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site.  These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect and process information on our behalf.  We may collect the information from use of these technical methods in a form that is personally identifiable.

During some visits to our Site, we may use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page.  We may use this information to measure Site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

How We Use Cookies

Our Site may use “cookies” to facilitate your ongoing access to and use of our Site, and helps us in the ongoing maintenance of our Site. Cookies are small text files that may be placed on your browser when you visit our web site.  For instance, when you return to the Site after logging in, cookies provide information to the Site, including personal information, so that the Site will remember who you are.

Using the settings of your Internet browser, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies.  Consult your browser’s HELP menu to learn your options with respect to cookies.  If you choose to turn off cookies, you may not have access to many features that make your browsing of our Site smoother, and some of our services may not function properly.  You may at any time delete any cookies by using the relevant option of your Internet browser or by deleting the cookies on your hard drive. 

If you continue to use the Site with a browser set to accepting cookies, we will assume that you accept receipt of all cookies coming from the Site. The collection of the foregoing information is for the purposes of our legitimate business interests (such as to carry out and improve our business, and to analyze the use of our Site and services).

Google Analytics

We use Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users visit the Site, what pages users visit, and what other sites they visited prior to or after coming to the Site. More information on how Google Analytics uses your data can be found at We use the information we get from Google Analytics only to improve the Site. By using the Site with your browser set to accepting cookies, you consent to Google Analytics’ use of cookies on the Site.

How We Use Information We May Collect

We do not share any nonpublic personal information collected from our Site with any unaffiliated third parties, except as set forth below. Personal information collected from our investors who choose to access the private, restricted area of our Site reserved for our investors, may be used (i) to supply the investment services you have requested and correspond with you, or otherwise perform our contract with you, (ii) to provide support to you in respect of these services, (iii) to improve our Site and services, and (iv) for our internal business processes.

We may use or disclose certain personal information we collect about you or that you provide when you visit and browse the Site as part of our normal business operations, including to respond to requests from you.  We may also use service providers in connection with the Site.  These companies and individuals may have access to and use your personal information, as needed to perform their functions.

We will disclose personal information we collect from you when we believe that such disclosures are required by law, regulation, legal process, subpoena, document or governmental request.  We may also do so to help enforce our Terms of Use, protect your safety or security, or protect the safety and security of tangible or intangible property that belongs to us, to you or to third parties.  Also, in the event that Rubicon, or any portion of our assets or businesses, are acquired by or merged with another entity, whether an affiliate or a third party, user information may be one of the transferred assets.  We may transfer all user information (which may include personal information) to our acquirers or successors.  Other than as part of such transaction, we will not sell any of your personal information without your consent.


As an organization based in the United States, Rubicon will collect and process certain personally identifiable information outside the European Economic Area (“EEA”), and data protection legislation in the EEA provides individuals in the EEA with certain data protection rights which we are obliged to inform such individuals of, namely (i) the right to receive confirmation as to whether we have personally identifiable information concerning you and, if so, access to that personally identifiable information and information concerning the nature and processing of such personally identifiable information, (ii) the right to rectify or update personally identifiable information that is incomplete or inaccurate, (iii) the right to erase personally identifiable information in certain circumstances, (iv) the right to restrict the use of your personally identifiable information in certain circumstances, (v) the right to ask us to stop processing your personally identifiable information in certain circumstances, (vi) the right to receive your personally identifiable information in a structured, commonly used and machine-readable format, (vii) the right to request that we transmit such data to another party, in certain circumstances, and (viii) the right to make a complaint to your applicable data protection supervisory authority.

In addition, it will sometimes be necessary for us to transfer EEA personally identifiable information to our staff with an affiliate and our third-party service providers outside the EEA. We will therefore take all steps reasonably necessary to ensure that relevant EEA personally identifiable information is only transferred if that party (i) is situated in a country that has been confirmed by the European Commission to provide adequate protection to personally identifiable information or (ii) has agreed (by way of written contract) to provide all protections to the EEA personally identifiable information as required by the applicable data protection legislation.

Protection of information and Network Security

We endeavor to protect your personal information.  We use technical, administrative and physical methods to maintain the integrity and security of our databases, including firewalls.  Please be aware though that there is no such thing as “perfect security” on the Internet, and third parties may unlawfully intercept or access transmissions or private communications.  We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personal information.  You use our Site and send us information at your own risk.

Access to Portfolio Company and Other Third Party Websites

Our Site contains links to websites controlled and maintained by our current or former portfolio companies and other third parties. We provide these links solely as a convenience for you. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites are used. This Privacy Policy does not govern the use of information collected on such third party websites. Should you choose to visit these third party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your personal information.

Do Not Track

We do not track visitors of the Site over time and across third party websites to provide targeted advertising and therefore do not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser allows you to set the DNT signal so that third parties (particularly advertisers) know you do not want to be tracked. You may consult the help pages of your browser to learn how to set your preferences so that websites do not track you.

Information Requests

You have the right to request that we disclose to you or delete certain information about our collection and use of your personal information. Once we receive your request and verify your identity, we will disclose such information to you or delete the same, unless a legal exception applies.  For example, we may deny your deletion request if retaining the information is necessary for us or our providers to complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

To exercise the rights described above, please submit a request to us by either:

  • Calling us at (303) 872-6950
  • Emailing us at

Your request must:

  • Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of such person.
  • Describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with non-public personal information if we cannot verify your identity or authority to make the request and confirm that the requested personal information relates to you.  We will use the information provided in a request solely to verify your identity or authority to make the request. 

California’s Shine the Light Law

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our Site users who are California residents to request and obtain from us a list of their personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. We currently do not share any personal information with third parties for their direct marketing purposes.

Governing Law

The laws of the State of Colorado govern this Privacy Policy.  Any dispute relating to this Privacy Policy or your use of the Site or the Content shall be resolved solely in the state or federal courts located in Denver, Colorado.  You agree to waive trial by jury in any such action.

Last updated December 2019.