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The policy states that LlamaIndex collects share purchasing history, number and value of shares held, and holder of record names and addresses from shareholders and investors, using this data for investor relations management, transaction processing, tax documentation, and cap table administration.
This analysis describes what LlamaIndex's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The policy explicitly identifies investors and shareholders as a distinct data subject category and describes specific financial and transactional personal data categories collected from them, including data used for tax reporting and investment transaction processing.
Under this clause, LlamaIndex shareholders and investors have their share ownership details, transaction history, and financial information collected and used for investor relations, tax preparation, and cap table management purposes as described in the policy.
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"In addition to the personal data practices outlined above, we also collect personal data from shareholders and investors of our company, including share purchasing history, number of shares held, value of the shares, and the holder of record's name and address. We use this information primarily to manage investor relations and investments in our company, including by providing you information about our company and related investments, processing investment transactions, preparing tax returns and other investor-related documents, and managing our cap table.Excerpt from LlamaIndex's Privacy Policy
1) REGULATORY LANDSCAPE: Collection and processing of investor and shareholder data may engage SEC regulations regarding record-keeping and disclosure obligations for private companies. Tax-related data processing implicates IRS reporting requirements. GDPR and state privacy laws apply to investor personal data to the extent those frameworks cover the relevant data subjects. 2) GOVERNANCE EXPOSURE: Low to medium. The disclosure that investor data may also be used for the broad additional purposes described in the policy's Additional Uses of Personal Data section, and may be disclosed to third parties under the Disclosure section, warrants review by investors regarding the secondary use scope. 3) JURISDICTION FLAGS: EU-based investors may have GDPR rights regarding their investor personal data. California-based investors may have CCPA rights. 4) CONTRACT AND VENDOR IMPLICATIONS: Investors reviewing this policy in connection with due diligence should note that their personal financial and ownership data may be shared with third-party service providers and in connection with business transactions as described in the broader disclosure section. 5) COMPLIANCE CONSIDERATIONS: Legal teams advising investors should confirm whether LlamaIndex's investor data practices are consistent with applicable securities law record-keeping requirements and whether adequate security measures are described for financial personal data.
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The policy explicitly identifies investors and shareholders as a distinct data subject category and describes specific financial and transactional personal data categories collected from them, including data used for tax reporting and investment transaction processing.
Under this clause, LlamaIndex shareholders and investors have their share ownership details, transaction history, and financial information collected and used for investor relations, tax preparation, and cap table management purposes as described in the policy.
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