Privacy Policy
Ponderosa Services Limited (the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through websites operated by us from which you are accessing this Privacy Policy (the “Websites”).
Personal Information
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Websites collect Personal Information, including: Name Email address IP address (we may also derive your approximate location from your IP address) Any information you choose to provide us with through our contact form.
Collection of Personal Information We collect Personal Information through your use of the Websites, for example, when you use our contact form. We need to collect Personal Information in order to process your requests or questions. If you do not provide the information requested, we cannot process your request or question. If you disclose any Personal Information relating to other people to us or to our service providers, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
USE OF PERSONAL INFORMATION We use Personal Information for the following purposes: Providing the functionality of the Websites and fulfilling your requests. To provide the Websites’ functionality to you, such as to respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our services. To send administrative information to you, such as changes to our terms, conditions, and policies. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation. Providing you with our newsletter and/or other marketing materials. To send you marketing related emails, with information about our services, new products and other news about our company. We will engage in this activity with your consent or where we have a legitimate interest. Analyzing Personal Information for business reporting. To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Websites. We will engage in this activity based on our legitimate interests. Aggregating and/or anonymizing Personal Information. We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. We will engage in this activity based on our legitimate interests. Accomplishing our business purposes. For data analysis, for example, to improve the efficiency of our Websites; For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements; For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft; For identifying usage trends, for example, understanding which parts of our Websites are of most interest to users; and For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users. We engage in these activities to comply with a legal obligation, and/or based on our legitimate interest.
Disclosure of Personal Information We disclose Personal Information: To our affiliates for the purposes described in this Privacy Policy. To our third party service providers, to facilitate services they provide to us. These can include providers of services such as fund administrators, website hosting, data analysis, fraud prevention, information technology and related infrastructure provision, email delivery, auditing, and other services.
Other Uses and Disclosures We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so: To comply with applicable law and regulations. This may include laws outside your country of residence. ·To cooperate with public and government authorities. To respond to a request or to provide information we believe is necessary or appropriate. These can include authorities outside your country of residence. To cooperate with law enforcement. For example, when we respond to law enforcement requests and orders or provide information we believe is important. For other legal reasons. To enforce our terms. In connection with a sale or business transaction. We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Other Information
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Websites collect Other Information such as: Browser and device information App usage data Information collected through cookies, pixel tags and other technologies Demographic information and other information provided by you that does not reveal your specific identity Information that has been aggregated in a manner such that it no longer reveals your specific identity
Collection of Other Information We and our service providers may collect Other Information in a variety of ways, including: Your browser or device. Certain information is collected from most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type. We use this information to ensure that the Websites function properly. Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Uses and Disclosures of Other Information We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
Choices and Access
Your choices regarding our use and disclosure of your Personal Information We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt out from receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the Unsubscribe link at the bottom of the email. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Retention Period
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: The length of time we have an ongoing relationship with you; Whether there is a legal obligation to which we are subject; or Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
Third Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Websites does not imply endorsement of the linked site or service by us or by our affiliates. In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer.
Use of Services by Minors
The Websites are not directed to individuals under the age of thirteen (13), and we do not knowingly collect Personal Information from individuals under 13.
Jurisdiction and Cross-Border Transfer
Your Personal Information may be stored and processed in the United Kingdom or United States, where we have facilities, affiliates or in which we engage service providers, and by using the Services you understand that your information may be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country. ADDITIONAL INFORMATION REGARDING THE UK: Some non-UK countries are recognized by the Secretary of State as providing an adequate level of data protection according to UK standards
For transfers from the UK to countries not considered adequate by the Secretary of State, we have put in place adequate measures, such as standard contractual clauses or binding corporate rules to protect your Personal Information. You may obtain a copy of these measures by contacting us in accordance with the “Contact Us” section below.
Sensitive Information
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Websites or otherwise to us.
Updates to this Privacy Policy
The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Websites.
Contacting Us
Ponderosa Services Limited is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at legal@galvanizeclimate.com, or:
 111 Sutter St, 10th Floor San Francisco, CA 94104
 Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
Additional Information Regarding the UK or EEA
You may also lodge a complaint with the Information Commissioner’s Office which is the UK regulator in charge of data protection and privacy enforcement.

TERMS OF USE
This page (together with the documents referred to on it) tells you the Terms and Conditions of Use (Terms of Use) on which you may make use of this website www.ponderosavc.com (the Website). Please read these terms of use carefully before you start to use our Website. By using our Website, you indicate that you accept the Terms of Use and that you agree to abide by them. If you do not agree to the Terms of Use, please refrain from using our Website.
1. Information about us
We are a Limited Company registered in England and Wales at Companies House under the Ponderosa Services Limited. Our registered office is at 7-10, Chandos Street, 6th Floor, North Suite, London, United Kingdom, W1G 9DQ and our company number is 13867289. We are an Appointed Representative of Sturgeon Ventures LLP whose FRN # 452811, which is authorised and regulated by the Financial Conduct Authority (the FCA) and entered on the Financial Services Register with the FRN # 452811  . If you have any queries about the Website or any information contained on it, please contact us by email at legal@galvanizeclimate.com
2. Accessing our website
Access to our Website is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our Website without notice. From time to time, we may restrict access to some or all of our Website. We will not be liable if for any reason our Website is unavailable at any time or for any period.  If you breach these Terms of Use, your permission to use the Website terminates immediately and you must immediately destroy any downloaded or printed extracts from the Website. You are responsible for making all arrangements necessary for you to have access to our Website. By accessing our Website any person using your computer agrees to be bound by these Terms of Use. You are responsible for ensuring that all persons who access our Website through your internet connection and on your computer are aware of these Terms of Use and that they comply with them. You are also responsible for the use of our Website by any person using your computer.
3. Disclaimer
Nothing on this Website is intended, nor should it be taken, to create any legal or contractual relationship. Any transmission, downloading or sending of any information from the Website does not create any contractual relationship. The content of the Website is designed for information purposes only. Neither the information nor any opinions stated in the Website constitutes a solicitation or offer by Ponderosa Services Limited to buy or sell any securities or other financial instruments or to provide any investment advice. The provision of investment services may be restricted in certain jurisdictions. It is your responsibility to acquaint yourself with any local laws and restrictions on the usage of thisWebsite and the availability of any services described on it. The information on this Website is not intended for distribution to or use by any personal entity in any jurisdiction or country where such distribution would be contrary to local law or regulation. The Services are available only to persons in the United Kingdom. The Services are not available to United States persons directly, unless introduced to Ponderosa Services Limited by a FINRA registered broker or their United States attorney. Nothing in this Website may be published in the press or elsewhere without permission of Ponderosa Services Limited. Ponderosa Services Limited does not provide legal or tax advice. Clients of Ponderosa Services Limited and viewers of this Website are encouraged to consult their own legal and tax advisers before making any investment decision. Private companies in all jurisdictions and potential investors should take independent legal and taxation and investment advice before proceeding with any type of fund raising activity.

While we endeavour at all times to ensure information on our Website is clear, fair and not misleading at the date of publication, we do not hold the information as impartial and it should not be viewed as wholly objective. Information on this Website is based on sources that we believe to be reliable but we give no undertaking that it is accurate or complete and Ponderosa Services Limited cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose or at all.  

The contents of this Website are subject to change without notice and Ponderosa Services Limited is under no obligation to report updates or amendments or keep information accurate. This Website is controlled and operated by Ponderosa Services Limited in the United Kingdom. We make no representations that materials in the Website are appropriate or available for use in other locations. Those who choose to access the Website from other locations do so at their own risk and are responsible for compliance with all applicable laws.
4. Intellectual Property Rights
This Website, its contents, any materials downloaded, and all intellectual property pertaining to or contained on the Website (including but not limited to copyrights, patents, database rights, graphics, designs, text, logos, trade dress, trademarks and service marks) are owned by or licensed to us and/or from third parties and all rights, title and interest in them shall remain the property of Pondoersa Services Limited and/or such third parties (collectively, the Content). The Content is protected by copyright, patent and trademark laws, and various other intellectual property rights and unfair competition laws. You are permitted to print copies and download extracts of the content on the Website for your own personal use for information purposes only, and may draw the attention of others within your organisation to material posted on the Website, subject to the following conditions: our status (and that of any identified contributors) as the authors of material on our Website must always be acknowledged;  you must not modify in any way the paper or digital copies of any materials you have printed off or downloaded, and you must not use any illustrations, photographs, video or audio sequences or graphics separately from any accompanying text; you must not duplicate, copy, publish, modify, create derivative works from, participate in the transfer of, post on the internet, or in any way distribute, redistribute or exploit our Website, or any portion of the Website, for any public or commercial use without our express prior written consent; you must not otherwise use any part of the Website in contravention of these Terms of Use. If you print off, copy or download any part of the Website in breach of these Terms of Use, your right to use the Website will cease immediately and you must, at our option, return to us or destroy any copies of the materials you have made.
5. Unlawful Or Prohibited Use
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We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses, trojans, worms, logic bombs or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our Website or to your downloading of any material posted on it, or on any website linked to it. You must not misuse our Website by knowingly or recklessly introducing viruses, trojans, worms, logic bombs or any other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our Website, the server on which our Website is stored or any server, computer or database connected to our Website. You must not attack our Website via a denial-of-service attack or a distributed denial-of service attack. Any such unauthorised use of our Website may give rise to a claim for damages and/or be a criminal offence under theComputer Misuse Act 1990. We will report any such activity to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our Website will cease immediately and without further notice.
6. Exclusion of Liability
The material displayed on our Website is provided without any guarantees, conditions or warranties as to its accuracy, originality or completeness. To the extent permitted by law, we and third parties connected to us hereby expressly exclude:
1.  all conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity;
2. any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our Website or in connection with the use, inability to use, or results of the use of our Website, any websites linked to it and any materials posted on it, including: (a) loss of income or revenue; (b) loss of business; (c) loss of profits or contracts; (d) loss of anticipated savings; (e) loss of data;( f) loss of goodwill; (g) wasted management or office time; and any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contractor otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.
In jurisdictions which do no tallow the exclusion or limitations of certain types of liability, Ponderosa Services Limited's liability will be limited to the maximum extent permitted by law.
7. Indemnity
By using our Website, you agree to indemnify and hold harmless Ponderosa Services Limited from and against any and all losses, claims, damages, costs and expenses (including reasonable legal and accounting fees) that Pondoersa Services Limited may become obliged to pay, arising or resulting from your use of our Website, the Content, or your breach of these Terms of Use. Ponderosa Services Limited reserves the right to assume or participate, at your expense, in the investigation, settlement and defence of any such action or claim.
8.  Links To Third Party Websites
Our Website may contain links to websites and resources maintained by third parties. These links are provided for your information only. We have no control over the contents of those websites and resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. We are not responsible for the content, availability or privacy policies of those sites, and the existence of such links should not be considered an endorsement or recommendation of those sites or of any product or service offered on those sites or of any party that is associated with those sites. Please note that other websites and resources linked to on our Website may be governed by separate terms and conditions, including privacy policies. You should refer to the applicable terms and conditions of those websites and resources before using them and you should direct any questions or comments about the linked website or resource to the appropriate website provider.
9. Linking To Our Website
You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such away as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link from any website that is not owned by you. Our Website must not be framed on any other website, nor may you create a link to any part of our Website other than the home page. We reserve the right to withdraw linking permission without notice. If you wish to make any use of material on our Website other than that set out above, please address your request to legal@galvanizeclimate.com.
10. Revision Of Terms
We may revise these Terms of Use at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you. Some of the provisions contained in these terms of use may also be superseded by provisions or notices published elsewhere on our Website.
11. Jusrisdiction And Applicable Law
The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our Website. We retain the right to bring proceedings against you for breach of these conditions in your country of residence or any other relevant country. These terms of use and any dispute or claim arising out of or in connection with them or their subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of England and Wales.
12. Miscellaneous
Any failure by Ponderosa Services Limited to exercise any rights or enforce any of these Terms of Use shall not constitute a waiver of such rights or terms. If any provision of these Terms of Use or their application in a particular circumstance is held to be invalid or unenforceable to any extent, the remainder of these Terms of Use, or the application of such provision in other circumstances, shall not be affected thereby, and each provision of these Terms of Use shall be valid and enforced to the fullest extent permitted by law. These Terms of Use (together with any documents referred to in them) constitute the entire agreement between you and Ponderosa Services Limited with regard to your use of our Website, and any and all other written or oral agreements or understandings previously existing between you and Ponderosa Services Limited with respect to such use are superseded and cancelled.





ANTI-BRIBERY AND CORRUPTION

Introduction

PONDEROSA SERVICES LIMITED  (the Firm) strongly values its adherence to and reputation for ethical behaviour, financial probity and reliability. It also fully recognises that the breach of any of these may also amount to the commission of a crime.  Its aim therefore is to limit its exposure to bribery by: Setting out a clear anti-bribery policy; Training all consultants and clients, so that they can recognise and avoid the use of bribery by themselves and others; Encouraging its consultants and clients to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately; Notifying all third parties that PONDEROSA SERVICES LIMITED  engages with its policy and has zero tolerance of bribery and/or corruption. Rigorously investigating instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution; Taking firm and vigorous action against any individual(s) involved in bribery. 

The Policy

PONDEROSA SERVICES LIMITED prohibits the offering, the giving, the solicitation, or the acceptance of any bribe, whether cash or other inducement:to or from any person or company, wherever they are situated and whether they are a public official or body or private person or company; by any individual consultant, agent or other person or body acting on PONDEROSA SERVICES LIMITED'S behalf; in order to gain any commercial, contractual or regulatory advantage for PONDEROSA SERVICES LIMITED in a way which is unethical; or in order to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual. 

Further Clarification

PONDEROSA SERVICES LIMITED recognises that market practice varies across the territories in which it does business and what is normal and acceptable in one place may not be in another. This policy prohibits any inducement which results in a personal gain or advantage to the recipient or any person or body associated with them, and which is intended to influence them to take action which may not be solely in the interests of the Firm or of the person or body employing or contracting with them or whom they represent. This policy is not meant to prohibit the following practices providing they are customary in a particular market, are proportionate and are properly recorded:normal and appropriate hospitality;the giving of a gift for a corporate reason or at another special time, as long as it is reported in the proper manner within the Firm on the gifts register.Inevitably, decisions as to what is acceptable may not always be easy. If anyone is in doubt as to whether a potential act constitutes bribery, the matter should be referred to the local senior manager with responsibility for this policy before proceeding. If necessary, guidance should also be sought from the Compliance Officer. Consultants and Principles Responsibility within PONDEROSA SERVICES LIMITED. The prevention, detection and reporting of bribery is the responsibility of all consultants throughout PONDEROSA SERVICES LIMITED. Suitable channels of communication by which consultants or others can report confidentially any suspicion of bribery will be maintained via the Firm’s anti-corruption reporting procedures.

Useful resource: www.transparency.org.uk for the Transparency Index A fuller Policy and Procedures outlining all the principles of the Bribery Act 2010 and the relevant FCA rules and guidance can be requested from the Compliance Officer of Sturgeon Ventures LLP, of whom PONDEROSA SERVICES LIMITED is an Appointed Representative firm, by emailing sw@sturgeonventures.com. 
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Ponderosa Services Limited is an Appointed Representative of Sturgeon Ventures LLP (FRN: 452811), which is authorised and regulated by the Financial Conduct Authority.