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Effective Date: 02/10/2020

INTRODUCTION

NestGSV Inc. and the Misk Foundation and their subsidiaries and affiliates (collectively, “GSVlabs and Misk”, “us”, “we” or “our”) created this privacy policy (“Privacy Policy”) to advise you about GSVlabs’ and Misk’s information practices, such as the types of information we collect and how we may use that information, and to inform you about your privacy rights and how the law protects you. We urge you to read this Privacy Policy carefully. Please also review our Terms of Use [LINK], which govern your use of the Sites (as defined below).

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Individuals in the European Union (“EU”) should be sure to read the important information provided in section XIII below, in addition to the other provisions in this Privacy Policy.

I. IMPORTANT INFORMATION AND WHO WE ARE

II. THE INFORMATION WE COLLECT ABOUT YOU

III. HOW IS YOUR PERSONAL INFORMATION COLLECTED

IV. THIRD PARTY INTERACTIONS

V. THIRD PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING

VI. HOW WE USE YOUR PERSONAL INFORMATION

VII. DISCLOSURES OF YOUR PERSONAL INFORMATION

VIII. YOUR CHOICES

IX. DATA SECURITY

X. USERS OUTSIDE OF THE UNITED STATES AND INTERNATIONAL TRANSFERS

XI. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

XII. QUESTIONS

XIII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION

I. IMPORTANT INFORMATION AND WHO WE ARE

A. APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to https://ewc.gsvlabs.com/ and all other websites, features, or online services that are owned or controlled by NestGSV Inc. and the Misk Foundation and that post a link to this Privacy Policy (collectively, the “Sites”), whether accessed via computer, mobile device, or otherwise. For convenience, we refer to the Sites and our services collectively as the “Service”. Note, however, this Privacy Policy does not apply to your use of unaffiliated websites that link to our Sites. Once you enter another website (whether through an advertisement, service, or content link), be aware that we are not responsible for the privacy practices of such other websites.

B. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how NestGSV Inc. and the Misk Foundation collect and use your Personal Information through your use of the Service, including any information you may provide through the Service when you sign up to receive communications, purchase a product or service, or request further services or information from us.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or using Personal Information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.

C. CHILDREN

The Service is not intended for children and we do not knowingly collect information relating to children. If NestGSV Inc. and/or the Misk Foundation discovers that it has inadvertently collected Personal Information from anyone younger than the age of 16, it will delete that information.

D. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 02/10/20.

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It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.

E. THIRD PARTY CONTENT, LINKS TO OTHER WEBSITES, AND NESTGSV INC. AND MISK FOUNDATION CONTENT FOUND OUTSIDE THE SITES

The Sites may include links to third-party websites, embedded content, plug-ins and applications and certain content on the Sites may be hosted and served by third parties that NestGSV Inc. and the Misk Foundation does not control. Clicking on those links, viewing or accessing embedded content (such as videos, gifs, or audio files), or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Sites, we encourage you to read the privacy policy of every website you visit.

In addition, NestGSV Inc. and the Misk Foundation content may be included on web pages and websites that are not associated with NestGSV Inc. or the Misk Foundation and over which we have no control. These third parties may collect data through the use of their own cookies, web beacons or other technology, independently collect information or solicit Personal Information, and may have the ability to track your use of their websites and services. NestGSV Inc. and the Misk Foundation are not responsible for the privacy practices or the content of any third party.

II. THE INFORMATION WE COLLECT ABOUT YOU

Personal Information or personal data means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (“Anonymous Data”).

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We do not intentionally collect any Special Categories of Personal Information about you (this includes Social Security numbers, details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

III. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect information from and about you, including through:

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• Community Features. The Service may provide you the opportunity to participate and post User Content publicly through reviews, surveys, interactive features, or other communication functionality (“Community Features”). We may provide functionality for you to submit or post User Content through Community Features, by linking the Sites to a third party service, or otherwise. Please note that certain information, such as your name, may be publicly displayed on the Sites along with your User Content. User Content consisting of uploaded files may contain metadata, which may contain Personal Information or other information about or relating to you. You may wish to remove metadata from your files before transmitting such files to NestGSV Inc. and the Misk Foundation. Note that anything you post through Community Features is public – others will have access to your User Content and may use it or share it with third parties. If you choose to voluntarily disclose Personal Information, that information will be considered public information and the protections of this Privacy Policy will not apply. If you submit User Content, it may be published online or offline at any time. In addition, we may use your User Content and any excerpt from your User Content in connection with our advertising, marketing, publicity and promotional activities.
• Third parties or publicly available sources. We may receive Personal Information about you from various third parties (including your employer, broker, host, parent or guardian) or public sources. For example, if you are on another website and you opt-in to receive information from us, the other website may forward your contact and other information to us so that we may contact you as requested. If your company has provided you with access to the Service, we may receive information about you from your company. We also may supplement the information we collect with outside records from third parties in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Service. In those cases, we will apply this Privacy Policy to the combined information. Examples of third party sources include:Technical Information from the following parties:analytics providers; advertising networks; and search information.Contact, Financial and Transaction Information from providers of technical, payment and delivery services.Contact and Financial Information from companies that facilitate making reservations.Identity and Contact Information from publicly available sources.

IV. THIRD PARTY INTERACTIONS

Certain functionality on the Sites may permit interactions that you initiate between the Sites and a third party website or service (“Third Party Interactions”). Examples of Third Party Interactions may include technology that enables you to “like” or “share” content from the Sites on or to other websites or services; to transmit content to the Service from your account on a third party website or service; and to otherwise connect the Service to a third party website or service, such as through an application programming interface (API) made available by NestGSV Inc., the Misk Foundation or a third party.

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The information we collect in connection with Third Party Interactions is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website or service.

V. THIRD PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING

NestGSV Inc. and the Misk Foundation work with certain third parties (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Sites, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. For example, if you clicked on one of our advertisements that led you to one of the Sites, our service provider(s) may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These third parties may set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics. We may share Device Identifier and Usage Data about visitors with third party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising.

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Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Sites currently do not alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.

VI. HOW WE USE YOUR PERSONAL INFORMATION

We may use the information we collect about you, including Personal Information and Usage Data for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service. We use your personal information:

• to provide, operate and improve the Service; to identify you as a user in our system; to process a transaction you initiate, process payments and provide accurate billing and shipping; to process your registration with the Sites, including verifying your Contact Information is active and valid; to bill you for NestGSV Inc. and the Misk Foundation products and services; to contact you with regard to your use of the Sites and, in our discretion, changes to the Sites policies or functionality; to communicate with you about the Service, including by sending you announcements, updates, security alerts, and support and administrative messages; to communicate with you about events or contests in which you participate; to understand your needs and interests, and personalize your experience with the Service; and to respond to your requests, questions and feedback related to the Service.

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With your consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

A. COMMUNICATIONS AND OFFERS FROM US

We may use your Identity, Contact, Technical, Usage, Business and Profile Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from, purchased goods or services from us, or if you provided us with your details when you registered out our Sites and, in each case, you have opted in to receive that marketing.

B. THIRD-PARTY AND AFFILIATE MARKETING

We do not share your Personal Information with unaffiliated third parties for those unaffiliated third parties' marketing purposes unless you consent to such sharing.

C. COOKIES

A cookie is a data file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless deleted by the user before the expiration date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies do not typically contain any information that personally identifies a user, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.

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Please note that blocking all cookies will have a negative impact upon the usability of many websites and if you choose to block cookies, you may not be able to use all the features on our Sites. For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org.

VII. DISCLOSURES OF YOUR PERSONAL INFORMATION\

We may share non-personally identifiable information, such as aggregated user statistics, in our discretion and without restriction.

We may disclose the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, or in the following circumstances:

A. INTERNAL THIRD PARTIES

NestGSV Inc. and the Misk Foundation may disclose information including Personal Information with its parent, subsidiaries and affiliates for a variety of purposes, including for business, operational, and marketing purposes. NestGSV Inc. and the Misk Foundation may, and reserves the right to, share your information with any other company that is not presently, but becomes, a NestGSV Inc. or Misk Foundation parent, subsidiary, or affiliate.

B. EXTERNAL THIRD PARTIES

Third Party Service Providers

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At your request, we will share information about you and your affiliated company with Mentors, Investors, and Members on the EWC Platform or GSV Passport. This allows us to make appropriate introductions on behalf of the user to Mentors, Investors, and other Members of the EWC Platform or GSV Passport.

C. SHARING BETWEEN NESTGSV INC. AND MISK FOUNDATION COMPANIES; BUSINESS TRANSFERS

NestGSV Inc. and the Misk Foundation may also disclose and transfer your Personal Information: (i) to a subsequent owner, co-owner or operator of the Sites or applicable database, or of our products or services; (ii) if NestGSV Inc. or the Misk Foundation (or any of their affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of NestGSV Inc.’s ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.

We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to use your Personal Information for specified purposes and in accordance with our instructions.

VIII. YOUR CHOICES

A. ACCESSING, UPDATING, CORRECTING OR DELETING INFORMATION

You can review, request access to, update, correct or delete your Personal Information by contacting us at community@gsvlabs.com.

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You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.

B. OPTING OUT

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.

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Where you opt out of receiving these marketing messages, this will not apply to Personal Information provided to us as a result of the purchase of a product or service or other transactions and we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

C. CHOOSING NOT TO SHARE PERSONAL INFORMATION

You may choose not to provide us with any Personal Information. In such an event, you may still be able to access and use some of the Sites; however, you may not be able to access and use those portions of the Sites that require your Personal Information. You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of any of the Sites (for example, administrative and service announcements, shipping notices, and order or reservation confirmations) and these transactional account messages may be unaffected if you opt-out from marketing communications.

Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

D. MARKETING COMMUNICATIONS

We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising. You can opt-out of such communications as outlined in Section B, above

Please note that you may continue to receive service-related and other non-marketing communications.

IX. DATA SECURITY

NestGSV Inc. and the Misk Foundation take commercially reasonable security measures to help protect your Personal Information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. However, please note that transmission over the Internet or wireless networks cannot be guaranteed to be completely secure; and therefore we cannot ensure or warrant the security of any information we collect. You use our Sites and provide us with your information at your own risk.

We have put in place procedures to respond to any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

X. USERS OUTSIDE OF THE UNITED STATES AND INTERNATIONAL TRANSFERS

The Sites are operated in the United States, and NestGSV Inc., the Misk Foundation and third party service providers and partners operate in the United States and other jurisdictions. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States and other countries. By using the Sites, or providing us with any information, you consent to this transfer, processing and storage of your information in countries where the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

XI. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information regarding NestGSV Inc. and the Misk Foundation’s disclosure within the immediately preceding calendar year of that California resident’s Personal Information to third parties (and in some cases, affiliates) for their direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request to the following email address: community@gsvlabs.com or write to us at the following mailing address: GSVlabs, 2955 Campus Dr #110, San Mateo, CA 94403. You must put the statement "Your California Privacy Rights" in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.

XII. QUESTIONS

If you have any questions or concerns regarding this Privacy Policy or our practices, please feel free to contact us via email at community@gsvlabs.com. We can also be contacted by mail at:

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2955 Campus Dr #110,

San Mateo, CA 94403

XIII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION

A. PERSONAL INFORMATION

References to “Personal Information” in this Privacy Policy are equivalent to “Personal Data” governed by European data protection legislation.

B. LEGAL BASES FOR PROCESSING PERSONAL DATA

We will only use your Personal Data when the law allows us to do so. Our legal basis for processing the personal information described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.

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Generally, we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us using the contact information provided above.

C. CONTROLLER

NestGSV Inc. and the Misk Foundation are made up of different legal entities.This Privacy Policy is issued on behalf of NestGSV Inc.. the Misk Foundation and their subsidiaries and affiliates so when we mention “GSVlabs”, “Misk” “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company responsible for processing your data. The Misk Foundation is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

D. DATA RETENTION

We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

E. CROSS-BORDER DATA TRANSFER

If we transfer your personal information from the European Economic Area to a country outside of it and are required to apply additional safeguards to your personal information under European data protection legislation, we will do so, for instance, by entering into standard contractual clauses for the transfer of data as approved by the European Commission. Please contact us for further information about any such transfers and the safeguards applied.

F. CHANGE OF PURPOSE

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at community@gsvlabs.com.

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Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

G. EU RESIDENT PERSONAL DATA RIGHTS

Under certain circumstances, EU Residents may have rights under data protection laws in relation to your Personal Data as outlined below:

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