Privacy Policy · Vertuem

Effective date: March 20, 2026

How we handle the limited information we collect through this website.

Vertuem builds and operates companies. We are not in the business of collecting data about the people who visit this site, and this policy reflects that. We keep a deliberately small footprint: there is no storefront here, no account to create, no password to forget, and no behavioral profile being assembled in the background. What follows is a complete and precise account of what we do collect, why, and the rights you hold over it.

1. Applicability

This Privacy Policy applies to the website located at vertuem.com (the “Site”) and to information collected by Vertuem LLC through the Site. It does not apply to any third-party website, platform, or service that may be linked from the Site, nor to the internal operations of the portfolio companies Vertuem builds or operates, each of which maintains its own policies where applicable.

The data controller responsible for personal information collected through the Site is Vertuem LLC, a limited liability company organized under the laws of the State of Delaware, with its principal place of business at 447 Broadway, New York, New York 10013, United States (“Vertuem,” “we,” “us,” or “our”). Where this policy refers to the “controller,” it means this entity.

By using the Site, you acknowledge that you have read and understood this policy. If you do not agree with it, the appropriate course is simply not to use the Site or submit information through it.

2. Information You Provide Voluntarily

Almost everything we hold about an individual is information that person chose to give us. We collect personal information only when you submit it through a contact form, an application or intake form, or by emailing us directly. Depending on which form you use, this may include:

Your name.
Your email address and, if you provide it, your phone number.
The name of a company or project you are associated with.
Any links, portfolio materials, or context you choose to include (for example, a website URL or a description of what you are building).
The substance of your message itself — the free-text content you write to us.

We do not require you to create an account, and we do not ask for sensitive categories of data (such as government identifiers, financial account numbers, health information, or data revealing racial or ethnic origin, political opinions, religious beliefs, or sexual orientation). Please do not submit such information to us; if you do, you do so on your own initiative and we will treat it under the same protections described here while encouraging its prompt deletion.

3. Information Collected Automatically

When you visit the Site, certain technical information is collected automatically by our hosting and analytics infrastructure, as is standard for virtually all websites. This may include:

Your IP address (which may be truncated or anonymized depending on our analytics configuration).
Browser type and version, operating system, and device type.
Referring URL and the pages you view on the Site, along with timestamps and approximate session duration.
General geographic location inferred from your IP address, at the level of region or country rather than precise location.

This information is aggregate and diagnostic in nature. We use it to understand how the Site performs and how visitors move through it, not to identify you personally. We do not attempt to combine this automatically collected data with the voluntary information described in Section 2 to build a profile of any individual.

4. How We Use the Information

We use the information we collect for a limited and specific set of purposes:

To respond to inquiries, applications, and messages you send us, and to follow up where a conversation warrants it.
To evaluate applications and potential working relationships, partnerships, or ventures.
To operate, maintain, secure, and improve the Site, including diagnosing technical problems and understanding usage patterns in aggregate.
To protect the Site and our rights, including detecting and preventing fraud, abuse, or unauthorized access.
To comply with legal obligations and respond to lawful requests from public authorities.

We do not use your information for advertising, we do not sell it, and we do not engage in automated decision-making that produces legal or similarly significant effects on you.

5. Legal Basis for Processing (EU / EEA / UK Visitors)

Where the European Union General Data Protection Regulation (“GDPR”) or the UK GDPR applies to our processing of your personal information — which is relevant given that Vertuem maintains operations in Amsterdam and regularly engages with applicants and counterparts in the EU — we rely on the following legal bases:

Consent. Where you voluntarily submit information through a form or by email, you consent to our processing it for the purpose for which you submitted it. You may withdraw that consent at any time (see Section 11), without affecting the lawfulness of processing carried out before withdrawal.
Legitimate interests. We process information to respond to inquiries, evaluate opportunities, secure and improve the Site, and run our business. We rely on legitimate interests only where those interests are not overridden by your rights and freedoms, and we have assessed that the limited, expected nature of this processing is consistent with what a reasonable visitor would anticipate.
Legal obligation. Where we must process or retain information to comply with applicable law, we rely on that obligation as our basis.

If you would like more detail on the balancing assessment behind any legitimate-interest processing, you may request it using the contact details in Section 14.

6. Cookies and Tracking Technologies

The Site uses a minimal set of cookies and similar technologies. These fall into two broad categories:

Strictly necessary. Cookies required for the Site to load and function correctly and securely. These cannot be disabled through our interface because the Site would not work properly without them.
Analytics. Cookies or comparable identifiers set by our analytics provider [INSERT ANALYTICS PROVIDER, e.g. Plausible / Fathom / Google Analytics] to help us understand aggregate Site usage. Where required by law, we request your consent before setting non-essential analytics cookies.

We do not use advertising cookies, cross-site tracking pixels, or third-party marketing trackers. You can control cookies through your browser settings, including blocking or deleting them, though doing so may affect how the Site functions. Where we deploy a consent banner, your choices there govern the setting of non-essential cookies.

We do not sell your personal information, and we never have. We share it only in the narrow circumstances below:

Service providers. We use a small number of third-party vendors to host the Site, deliver email, and provide analytics. These providers process information only on our instructions and only to the extent necessary to perform their service. Where required, they are bound by written data-processing agreements.
Legal compliance and protection. We may disclose information where we reasonably believe it is required to comply with a law, regulation, legal process, or enforceable governmental request, or where disclosure is necessary to protect the rights, property, or safety of Vertuem, our visitors, or others.
Business transfers. If Vertuem is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to the receiving party honoring the commitments in this policy.

Beyond these, we do not disclose your information to third parties without your consent.

8. Cross-Border Data Transfers

Vertuem maintains operations in New York, Amsterdam, and Hong Kong, and our service providers may store or process data in the United States and elsewhere. This means that information you submit — including from within the EU, EEA, or UK — may be transferred to, stored in, or accessed from countries whose data-protection laws differ from those in your home jurisdiction, including the United States.

Where we transfer personal information out of the EEA, the UK, or Switzerland to a country that has not received an adequacy decision, we put in place an appropriate transfer mechanism. In practice this means we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), together with any supplementary measures necessary to ensure your information receives a level of protection consistent with the GDPR. You may request a copy of the relevant transfer safeguards using the contact details in Section 14.

9. Data Retention

We keep personal information only for as long as it serves the purpose for which it was collected, after which we delete it or render it anonymous. In concrete terms:

Inquiries and general correspondence are retained while the conversation is active and for a reasonable period afterward, typically no longer than twenty-four (24) months, unless they mature into an ongoing relationship.
Applications and intake submissions are retained for the duration of our evaluation and, where the relationship does not proceed, for a limited period thereafter — typically no longer than twenty-four (24) months — so we can revisit promising contacts, unless you ask us to delete them sooner.
Automatically collected analytics data is retained in aggregate or pseudonymized form for the period configured with our analytics provider.

Where we are required by law to retain certain information for longer, we will do so and then delete it once the obligation expires. The specific periods above are defaults and may be shortened on request where no overriding legal or operational reason requires retention.

10. Security

We take reasonable and appropriate technical and organizational measures to protect personal information against unauthorized access, loss, misuse, or alteration. These include encryption of data in transit, access controls limiting who within our team and our network of specialists can view submissions, and reliance on reputable infrastructure providers.

No method of transmission over the internet or method of electronic storage is completely secure, however, and we cannot guarantee absolute security. You provide information to us at your own risk, and we encourage you not to send anything through the Site that you would consider highly sensitive.

11. Your Rights

Depending on where you live, you have rights over the personal information we hold about you. We honor these rights regardless of jurisdiction wherever it is practicable to do so.

Rights under the GDPR (EU / EEA / UK)

If you are in the EU, EEA, or UK, you have the right to:

Access. Obtain confirmation of whether we process your personal information and, if so, a copy of it.
Rectification. Have inaccurate or incomplete information corrected.
Erasure. Request deletion of your personal information (the “right to be forgotten”), subject to legal exceptions.
Restriction. Request that we limit our processing of your information in certain circumstances.
Portability. Receive the information you provided to us in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible.
Objection. Object to processing carried out on the basis of legitimate interests.
Withdrawal of consent. Withdraw any consent you have given, at any time, without affecting prior lawful processing.

You also have the right to lodge a complaint with a supervisory authority. For visitors in the Netherlands, this is the Autoriteit Persoonsgegevens (Dutch Data Protection Authority); visitors elsewhere in the EEA or UK may contact their local authority.

Rights under the CCPA / CPRA (California)

If you are a California resident, you have the right to know what personal information we collect and how we use and disclose it, the right to request deletion of your personal information, the right to correct inaccurate information, and the right not to be discriminated against for exercising these rights. Because we do not sell or share personal information for cross-context behavioral advertising, there is no “sale” or “share” for you to opt out of, but you may still exercise your other rights.

How to exercise your rights

To exercise any of these rights, contact us using the details in Section 14. We will respond within the timeframe required by applicable law (generally one month under the GDPR and forty-five days under California law, each extendable where permitted). We may need to verify your identity before acting on a request, in order to protect against unauthorized disclosure. Exercising your rights is free in ordinary circumstances.

12. Children’s Privacy

The Site is directed to businesses, founders, operators, and professionals — not to children. We do not knowingly collect personal information from anyone under the age of sixteen (16), and the Site offers nothing intended to appeal to children. If we learn that we have inadvertently collected personal information from a child under 16 (or under 13 where U.S. law sets that threshold), we will delete it promptly. If you believe a child has provided us with information, please contact us so we can remove it.

13. Links to Third-Party Sites

The Site may contain links to external websites, including those of portfolio companies, partners, or tools we reference. We provide these links for convenience and context only. We do not control those sites and are not responsible for their content, practices, or privacy policies. Once you leave the Site, this policy no longer governs; we encourage you to review the privacy policy of any site you visit.

14. Contact

If you have questions about this policy, wish to exercise your rights, or want to raise a concern about how we handle your information, you can reach the controller at:

Vertuem LLC
Attn: Privacy
447 Broadway
New York, New York 10013, United States
Email: hello@vertuem.com

We read what comes in. We will do our best to resolve any concern directly and promptly before you feel the need to escalate it elsewhere.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our infrastructure, or the law. When we do, we will revise the “Last updated” date at the top of this page, and where the changes are material we will take reasonable steps to bring them to your attention. Your continued use of the Site after an update takes effect constitutes acceptance of the revised policy. We encourage you to review this page periodically.