Updated as of July 2020
Unless noted otherwise, references on the website to the “Polaris Main Funds” represent the funds managed by North Star Venture Management 2010, L.L.C. (i.e., Polaris Venture Partners I, L.P., Polaris Venture Partners II, L.P., Polaris Venture Partners III, L.P., Polaris Venture Partners IV, L.P., Polaris Venture Partners V, L.P., Polaris Venture Partners VI, L.P., Polaris Partners VII, L.P., Polaris Partners VIII, L.P., Polaris Partners IX, L.P., and Polaris Healthcare Technology Opportunities Fund, L.P., as well as any alternative investment vehicles and side funds).
LS Polaris Innovation Fund, L.P. (“LSPIF”) is a specialized affiliate fund of Polaris Partners that is managed by its adviser, LS Polaris Innovation Fund Management, L.L.C.
Polaris Growth Fund I, L.P. (“PGF”) is also a specialized affiliate fund of Polaris Partners that is managed by its adviser, Polaris Growth Management, L.L.C. PGF makes levered recapitalizations of software and technology-enabled services companies across a variety of industry verticals.
NO OFFER OF SECURITIES OR ADVICE
The website contains general information about Polaris and its portfolio and is directed at entrepreneurs interested in partnering with Polaris and for individuals considering possible employment with Polaris. Nothing on this website is an offer or solicitation to buy or sell any security, including, without limitation, any interested in any investment vehicles managed by Polaris or any company in which Polaris, any Polaris fund, or any of their respective affiliates, have invested. Although the website may include investment-related information, nothing on this website is a recommendation that you purchase, sell or hold any security or other investment, or that you pursue any investment style or strategy. Nothing on this website is intended to be, and you should not consider anything on the website to be, investment, accounting, tax or legal advice.
An offer regarding any Polaris fund may only be made after receipt of a confidential private placement memorandum concerning a particular fund and the opportunity to discuss all matters concerning any prospective investment. This website is not intended for prospective investors in Polaris funds and does not provide information material to an investor’s decision to invest in any Polaris fund, including, but not limited to, risk factors. For such information, investors should refer to the relevant fund’s private placement memorandum.
The website may include current and historical portfolio companies. Such references are for illustrative purposes only and do not represent all Polaris portfolio companies. A full list can be found here.
The information contained in the website may include certain historical investment performance information and forward-looking statements relating to the Polaris funds as well as to their underlying portfolio companies. Forward-looking statements are not guarantees of the underlying expected actions or future performance and future results may differ significantly from those anticipated by the forward-looking statements. Past performance is not indicative of future results and there can be no assurance that future performance will be comparable to past performance.
All content included on this website, such as documents, charts, graphics, logos, articles and other materials, is the property of Polaris or others and is protected by copyright and other laws. All trademarks and logos displayed on this website are the property of their respective owners, who may or may not be affiliated with Polaris.
RESTRICTIONS ON USE
RISKS YOU ASSUME BY USING THE WEBSITE
Information on the website speaks only as of the date indicated. While we make reasonable efforts to provide accurate information, at times we may not promptly update or correct the website even if we are aware that it is inaccurate, outdated or otherwise inappropriate. You agree that we are not responsible for any action that you take or decision you make in reliance on any information contained in the website.
While we make commercially reasonable efforts to ensure that the website is secure, we do not guarantee the security of the website or your communications with us through the website. Electronic communications can be intercepted by third parties and, accordingly, transmissions to and from this website may not be secure. Communications to Polaris, particularly those containing confidential information, may be sent by mail to: Polaris Partners, One Marina Park Drive, 10th Floor, Boston, MA 02210, attn: General Counsel. Polaris shall be free to use, for any purpose, any ideas, concepts, know-how, or techniques provided by you to Polaris through this website.
THIRD PARTY WEBSITES
Due to the global nature of the Internet, this website 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 website, 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. In addition information collected from users outside the United States may be transferred to the United States and other countries.
DISCLAIMER OF WARRANTIES
You acknowledge that we provide the contents of this website on an “as is” basis with no warranties of any kind. We disclaim all representations and warranties, express or implied of any kind with respect to the website, including warranties of merchantability, fitness for a particular purpose and non-infringement of intellectual property and proprietary rights. Without limiting the foregoing, we do not warrant the availability, accuracy, completeness, timeliness, functionality, reliability, speed or delivery of the website or any part of the information contained in this website. Your use of this website and use or reliance upon any of the materials on it is solely at your own risk.
Neither we nor any of our agents, members, managers, officers, directors or employees are responsible for any damages, liabilities or injury, including but not limited to direct, indirect, incidental, special, exemplary, punitive or consequential damages, or for any lost profits or losses, however caused, arising out of your use of (or inability to use) this website, whether arising under this Agreement or otherwise. Our liability is limited to the maximum extent permitted by law and is limited even if we have been advised of the possibility of the damages, liability or injury that you suffer or if any remedy you have fails of its essential purpose, including any damages, liabilities or injury caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, line failure, or other computer malfunction.
In exchange for using this website, you agree to indemnify and hold Polaris, our agents, members, directors and employees harmless against any and all claims, losses, liabilities, costs and expenses (including, but not limited to, attorneys’ fees) arising from your use of this website or your violation of this Agreement. In addition, you understand and agree that your use of this website is predicated upon your waiver of any right to sue Polaris, our agents, members, managers, officers, directors and employees directly or to participate in a suit for any losses or damages resulting from your use of this website.
Notwithstanding the foregoing, nothing contained in preceding paragraphs or elsewhere in this Agreement shall constitute a waiver by you of any of your legal rights under applicable U.S. federal securities laws or any other laws whose applicability is not permitted to be contractually waived.
Polaris may terminate your access to this website for any reason, without prior notice. The Agreement shall survive any termination or expiration of your access to the website.
The laws of the Commonwealth of Massachusetts, without regard to its principles of conflict of laws, will govern this Agreement (including any disputes concerning or related to this Agreement). You hereby expressly agree to submit to the exclusive personal jurisdiction of the federal and state courts sitting in Boston, Massachusetts for the purpose of resolving any dispute relating to your access to or use of the website. You agree to bring any claim solely in your individual capacity and you expressly waive any right to bring any claim as part of a group or as a class action.
If any provision of the Agreement is deemed unlawful, void, or for any reason unenforceable, than that provision will be deemed severable from the Agreement and will not affect the validity and enforceability of the remaining provisions. The Agreement constitutes the entire agreement and understanding between you and Polaris, and supersedes any prior agreement and understandings with respect to your access to or use of the website.
Updated as of January 2020
Who is responsible for the processing of your data?
We have offices in United States of America. North Star Venture Management Ireland Limited is our representative in the European Union and is registered with the Irish Companies Registration Office. We will be considered the Data Controller of the information collected through the website.
Should you wish to contact our offices, they may be found at:
One Marina Park Drive, 10th Floor, Boston, MA 02210
One Letterman Drive, Suite C3600, San Francisco, CA 94129
150 West 28th Street #904, New York, NY 10001
Who can you contact if you have questions or requests?
Address: One Marina Park Drive, 10th Floor, Boston, MA 02210
Phone: (781) 290-0770
We value the personal data entrusted to us and are committed to processing your personal data in harmony with the data protection laws and regulations to which Polaris is subject, including the EU General Data Protection Regulation and the California Consumer Privacy Act (“Data Protection Laws”). The terms “personal data” and “personal information,” as used herein, refers specifically to information that identifies a visitor to this website (which may include information referred to as “Personal Information” under the California Consumer Privacy Act (“CCPA”)).
We will aim to adhere to the following key principles:
Lawfulness: We will only collect your personal data in a fair, lawful and transparent manner.
Data minimization: We will limit the collection of your personal data to what is directly relevant and necessary for the purposes for which they have been collected.
Purpose limitation: We will only collect your personal data for specified, explicit and legitimate purposes and not process your personal data further in a way incompatible with those purposes.
Accuracy: We will keep your personal data accurate and up to date.
Data security and protection: We will implement technical and organizational measures to ensure an appropriate level of data security and protection considering, amongst other things, the nature of your personal data to be protected. Such measures provide for the prevention of any unauthorized disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of processing.
Access and rectification: We will process your personal data in line with your legal rights.
Retention limitation: We will retain your personal data in a manner consistent with the applicable Data Protection Laws, and no longer than is necessary for the purposes for which it has been collected.
Protection for international transfers: We will ensure that any of your personal data transferred outside the EEA is adequately protected.
Safeguards towards third parties: We will ensure that personal data access by, and transfers to, third parties are carried out in accordance with applicable law and with suitable contractual safeguards.
Processing your personal data
Automatically collected information
Polaris may collect information during your visit to the website through automatic data collection tools, which may include cookies (see below for more information on cookies) and other commonly used information-gathering tools. These tools collect certain information that your browser sends to our website such as your browser type and language, access times, and the address of the website from which you arrived at the Polaris website. They may also collect information about your Internet Protocol (IP) address and clickstream behavior (i.e. the pages you view, the links you click, and other actions you take in connection with the website), geolocation data, and information about your device. Polaris may also share this information in aggregate form (i.e., that cannot reasonably identify a particular individual) with third parties for business purposes, such as service providers and consultants to Polaris.
Legal basis for processing
- you have given us your consent for the purposes of the processing; or
- it is necessary for the performance of a contract to which you are a party; or
- we have a legitimate interest that is not outbalanced by your privacy rights; or
- it is required under a legal obligation to which we are bound.
For the avoidance of doubt, you will always have the right to withdraw your consent at any time.
Protecting your personal data
We have a set of reasonable technical and organizational security measures in place to protect your personal data against unlawful or unauthorized access or use, as well as against accidental loss or damage to its integrity. They have been designed by taking into account our IT infrastructure, the potential impact on your privacy, the costs involved and the current industry standards and practice.
Our data security procedures include: access security, backup systems, monitoring, review and maintenance, management of security incidents and continuity. Your personal data will only be processed by a third-party Data Processor if they agree to comply with those technical and organizational data security measures.
Disclosure of personal data & third parties
Depending on the purposes for which we collect your personal data, we may disclose it to the following categories of recipients, which will then process your personal data only within the framework of these purposes:
- authorized staff members of Polaris;
- entities and persons affiliated with the Polaris family of funds, and their related management companies and other affiliated entities; and
We do not sell or rent your personal information for valuable consideration.
Transfers outside the EEA
Your personal data will be processed outside the EEA. When there is any transfer of your personal data to countries outside the EEA that do not generally offer the same level of data protection as that within the EEA, Polaris will implement appropriate specific measures to ensure an adequate level of protection of that personal data. As an example, these measures can include agreeing on binding contractual clauses with recipients that guarantee adequate levels of protection.
Your choices and rights
We want to be as transparent as possible with you, so that you can make meaningful choices.
Under the Data Protection Laws, you are entitled to the following:
- a right of access to your personal data;
- a right to object to the processing of your personal data in certain circumstances;
- a right to rectify any information which is inaccurate;
- a right to the erasure of your personal data (also known as the “right to be forgotten”); provided that Polaris may retain your information only if it necessary to provide you with services you requested or for our internal analytical use
- a right to data portability when the processing activity is based on consent or under a contract with the you, i.e. the right to receive your data or to have the data transmitted to a third party;
- a right to ask us to restrict the processing of your personal data if you have challenged the accuracy of your data, or if you have objected to the use of your data. You may also ask us to limit the use of your data where you feel we may have processed your data unlawfully, or where you want us to keep your personal data in order to create, exercise or defend legal claims; and
- a right to not be discriminated for exercising your rights under the Data Protection Laws.
If personal information is being processed with your consent, you may withdraw this at any time. You also have the right to lodge a complaint with the supervisory authority or seek judicial remedy. These rights can be exercised verbally or in writing by emailing firstname.lastname@example.org.
If you are not happy with the way we manage your data, disagree with a decision we have made in respect to your individual rights, or you have any other type of concern, you may raise a complaint by contacting us.
If you are dissatisfied with the way your issue was dealt with, you may also lodge an official complaint with the supervisory authority in your jurisdiction at any time.