First Round - Website Privacy Policy (8-14-2025)
Privacy Policy
Effective date: 8/22/2025
Thank you for visiting https://www.firstround.com/ or https://review.firstround.com/ (the “Site”) owned and operated by FR Capital Holdings, L.P. (“First Round”). At First Round, we take your privacy seriously. Whether you are visiting the Site as an investor, founder, or member of the general public, you are entitled to certain information and rights relating to your personal data. Please read this Privacy Policy to learn how we treat your personal data.
By using or accessing our Site in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of First Round’s Site is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
As we continually work to improve our Site, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the Site, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Site, and you are still responsible for reading and understanding them. If you use the Site after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.
Privacy Policy Table of Contents
What this Privacy Policy Covers
Personal Data
- Categories of Personal Data We Collect
- Our Commercial or Business Purposes for Collecting Personal Data
- Other Permitted Purposes for Processing Personal Data
- Categories of Sources of Personal Data
How We Disclose Your Personal Data
Tracking Tools, Advertising and Opt-Out
Data Security
Personal Data of Children
California Resident Rights
Exercising Your California Rights
Other State Law Privacy Rights
Contact Information
What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Site, but does not cover the practices of companies we don’t own or control or people we don’t manage, nor to the privacy practices of any entity with whom we have an investment relationship, even if you are able to access such entity’s website or service through a link on the Site. It also does not apply to information obtained or disclosed in offline correspondence or in connection with an investment in one of our affiliated investment funds.
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations.
Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
| Category of Personal Information | Business or Commercial Purpose(s) for Collection | Categories of Third Parties With Whom We Disclose this Personal Information: |
|---|---|---|
| Profile or Contact Data • First and last name • Email • Address | Providing, customizing and improving the Site Corresponding with you | Service Providers Business Partners Parties You Authorize, Access or Authenticate |
| Professional or Employment-Related Data • Resume Job title Job history | Providing, customizing and improving the Site Corresponding with you | Service Providers Parties You Authorize, Access or Authenticate |
| Social Network Data Information from publicly-available LinkedIn profiles, such as name, job title, and job history. | Corresponding with you | Service Providers Business Partners |
| Device/IP Data IP address Device ID Domain server MAC address Type of device/operating system/browser used to access the Site Mobile network information (if applicable) | Providing, customizing and improving the Site Corresponding with you | Service Providers Parties You Authorize, Access or Authenticate |
| Web Analytics Web page interactions Referring webpage/source through which you accessed the Site | Providing, customizing and improving the Site Corresponding with you | Service Providers Business Partners Parties You Authorize, Access or Authenticate |
| Non-identifiable request IDs Statistics associated with the interaction between device or browser and the Site | ||
| Other Identifying Information that You Voluntarily Choose to Provide Identifying information in emails, letters, or texts you send us | Providing, customizing and improving the Site Corresponding with you | Service Providers Business Partners Parties You Authorize, Access or Authenticate |
Our Commercial or Business Purposes for Collecting Personal Data
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.
- 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 Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”).
Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about First Round or the Site.
- Sending emails and other communications according to your preferences.
Other Permitted Purposes for Processing Personal Data
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, First Round or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
You
- When you provide such information directly to us.
- When you create an account with us or our service providers, such as Circle.co, Ghost.org, or when using our interactive tools and 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 via Cookies.
Third Parties
- Vendors
- We may receive certain information about employees of our portfolio companies from these vendors.
- Vendors
How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers. These parties help us provide the Site or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
- Security and fraud prevention consultants.
- Analytics providers.
Business Partners. These parties partner with us in offering various services. They include:
- Businesses that you have a relationship with, including our investment fund affiliates.
Parties You Authorize, Access or Authenticate
- Third parties you authorize or direct us to share data with.
Legal Obligations
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Site and promote our business.
Tracking Tools, Advertising, and Opt-Out
The Site uses cookies and similar technologies 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.
Please note that because of our use of Cookies, the Site does not support "Do Not Track" requests sent from a browser at this time. We use various types of Cookies:
- Essential Cookies
- Functional Cookies
- Performance/Analytical Cookies
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Site or to perform our business or commercial purposes for collecting your Personal Data.
Personal Data of Children
We do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Site or send us any Personal Data.
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.
Access
You have the right to request certain information about our collection and use of your Personal Data.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you.
Personal Data Sales and Shares Opt-Out
We will not sell or share your Personal Data, and have not done so over the last 12 months.
Limit the Use of Sensitive Personal Information
Consumers have certain rights over the processing of their Sensitive Personal Information. However, we do not collect Sensitive Personal Information.
We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA
We will not discriminate against you for exercising your rights under the CCPA.
Exercising Your California Rights
To exercise the rights described in this Privacy Policy, you or your Authorized Agent must send us a request.
Other State Law Privacy Rights
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data.
Contact Information:
If you have any questions or comments about this Privacy Policy, please do not hesitate to contact us at: ccpa@firstround.com.