Privacy Policy - Sable

Last updated March 16, 2026

Sequel Technologies, Inc. and its affiliates ("Sequel," "we," "our," and/or "us") value the privacy of individuals who use Sable, our Angel Portfolio application and related services (collectively, the "Tool" or "Services"). This privacy policy (the "Privacy Policy") explains how we collect, use, and disclose information from angel investors who use the Services ("Users" or "you"). By using the Tool, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes.

For information about how we collect, use, share, and otherwise process your personal information as a financial institution, please refer to our GLBA Privacy Notice.

Summary of Key Privacy Commitments

We are committed to protecting your privacy and handling your angel portfolio data with the highest level of care:

  • Your data is yours. You can access, export, and delete your data at any time.
  • We don't sell your data. We will never sell your personal information or portfolio data to third parties.
  • Security is paramount. We use encryption, access controls, and industry-leading security practices to protect your information.
  • Transparency matters. We clearly explain what data we collect and how we use it.
  • You control your data. You decide what information to provide and can manage your preferences and privacy settings.
  • Minimal sharing. We only share your data with service providers necessary to operate the Tool, and they are contractually bound to protect it.
  • Compliance focused. We comply with applicable privacy laws and regulations, including GDPR, GLBA, and other frameworks.

Thank you for trusting Sequel with your angel portfolio data. We take that responsibility seriously and are committed to earning and maintaining your trust.

Overview of the Services

Sable is designed to help angel investors organize, track, and manage their portfolio investment data. You provide us with information about your angel investments, and we structure, analyze, and present this data in an organized, accessible format. This may include investment documents, transaction records, company information, performance data, and related materials.

Information We Collect

We collect various types of information to provide and improve the Services.

A. Information You Provide to Us

Registration and Account Information

When you create an account on Sable, we collect:

  • Your first and last name
  • Email address
  • Company or entity name (if investing through an entity)
  • Password and authentication credentials

Portfolio Investment Data

To organize your portfolio, you provide us with detailed information about your angel investments, including:

  • Company names, descriptions, and industry sectors
  • Investment dates, amounts, and valuations
  • Types of securities held (e.g., common stock, preferred stock, SAFEs, convertible notes)
  • Shareholding percentages and dilution history
  • Cap table information
  • Investment round details (seed, Series A, etc.)
  • Founder and key executive information
  • Company contact information
  • Geographic location of investments
  • Investment status (active, exited, written off)
  • Exit information (acquisition details, returns, multiples)
  • Notes, tags, and categorization you assign to investments

Investment Documents and Files

You may upload or share documents related to your angel investments, which may include:

  • Subscription agreements
  • Shareholder agreements
  • Stock certificates
  • SAFE or convertible note agreements
  • Term sheets
  • Capitalization tables
  • Board materials and updates
  • Financial statements and reports
  • Pitch decks and business plans
  • Correspondence with portfolio companies
  • Tax documents (K-1s, 1099s, etc.)
  • Legal and regulatory filings
  • Any other documents you choose to upload

Communications

When you contact us for support or communicate through the Services:

  • Email correspondence
  • In-app messages and chat transcripts
  • Phone call records (if you contact us by phone)
  • Feedback, feature requests, and survey responses

B. Information We Collect Automatically

Usage Information

We automatically collect information about how you interact with the Services:

  • Pages and features you access
  • Search queries and filters you apply
  • Time spent on different sections
  • Actions you take (uploading documents, creating tags, generating reports)
  • Dates and times of your visits
  • Frequency of use

Device and Technical Information

We collect technical information about your device and connection:

  • IP address and general location information (derived from IP)
  • Device type, model, and operating system
  • Browser type and version
  • Device identifiers
  • Screen resolution and display settings
  • Internet service provider
  • Referring and exit pages

Cookies and Similar Technologies

We and our service providers use cookies, pixel tags, local storage, and similar technologies to:

  • Remember your preferences and settings
  • Authenticate your account and maintain your session
  • Analyze usage patterns and improve the Services
  • Provide personalized features and recommendations
  • Measure the effectiveness of our communications

You can control cookie settings through your browser, but disabling certain cookies may limit your ability to use some features of the Tool.

C. Information from Third-Party Sources

Portfolio Data Integrations

With your authorization, we may collect investment data from third-party platforms and services you use including email providers (to extract investment updates and documents) or other portfolio tracking or investment management tools.

Publicly Available Information

To enhance your portfolio data and provide additional context, we may collect publicly available information about your portfolio companies from:

  • Company websites and press releases
  • Business registries and corporate filings
  • News articles and media coverage
  • Funding databases (Crunchbase, PitchBook, etc.)
  • Social media and professional networks
  • Industry reports and market data providers

How We Use the Information We Collect

We use the information we collect for the following purposes:

Providing and Improving the Tool

  • Organize, structure, and display your portfolio investment data
  • Generate reports, analytics, and visualizations
  • Track portfolio performance, returns, and metrics
  • Provide search, filtering, and categorization functionality
  • Store and manage your investment documents securely
  • Synchronize data across your devices
  • Develop new features and functionality
  • Identify and fix technical issues and bugs
  • Conduct research and analysis to improve the Tool

Communication and Support

  • Respond to your questions, requests, and support needs
  • Send you service-related notifications and updates

Security and Fraud Prevention

  • Verify your identity and authenticate your account
  • Detect, prevent, and investigate fraud or unauthorized access
  • Monitor for security threats and vulnerabilities
  • Comply with legal and regulatory requirements
  • Enforce our Terms of Service and other policies
  • Protect the rights, property, and safety of Sequel, our users, and others

Analytics and Aggregated Insights

  • Generate anonymized, aggregate statistics about angel investing trends
  • Analyze usage patterns to understand how the Tool is used

Legal and Compliance

  • Comply with applicable laws, regulations, and legal processes
  • Respond to lawful requests from government authorities
  • Enforce our legal rights and obligations

With Your Consent

  • Send you marketing communications (only with your opt-in consent)

How We Share and Disclose Information

We take your privacy seriously and limit how we share your information.

Service Providers and Vendors

We share information with third-party service providers who perform services on our behalf, including:

  • Cloud hosting and infrastructure providers
  • Artificial Intelligence tools
  • Database and data storage services
  • Authentication and identity verification services
  • Analytics and monitoring services
  • Security and fraud detection services
  • Document processing and OCR services
  • Email delivery services
  • Backup and disaster recovery providers

These service providers are contractually obligated to use your information only to provide services to us and to protect your information consistent with this Privacy Policy.

Affiliates

We may share information with our current or future corporate affiliates, subsidiaries, and parent companies for purposes consistent with this Privacy Policy.

Business Transfers

If Sequel is involved in a merger, acquisition, reorganization, sale of assets, bankruptcy, or other business transaction, your information may be transferred as part of that transaction. The acquiring entity will be required to honor the commitments made in this Privacy Policy.

Legal Requirements and Protection

We may disclose your information when we believe in good faith that disclosure is necessary to:

  • Comply with applicable laws, regulations, or legal processes
  • Respond to lawful requests from government authorities or law enforcement
  • Enforce our Terms of Service or other agreements
  • Investigate potential violations of our policies
  • Detect, prevent, or address fraud, security, or technical issues
  • Protect the rights, property, or safety of Sequel, our users, or the public as required or permitted by law

With Your Consent

We may share your information with third parties when you give us specific permission to do so, such as sharing portfolio data with your accountant, tax advisor, or financial advisor.

Aggregated and De-Identified Data

We may share anonymized, aggregated, or de-identified information that cannot reasonably be used to identify you. This may include aggregate statistics about portfolio performance and anonymous usage statistics.

This de-identified data does not contain personal information or specific investment details that could identify you or your portfolio companies.

Data Security and Protection

We implement comprehensive security measures to protect your information:

Technical Safeguards

  • Encryption of data in transit using TLS 1.3 or higher
  • Encryption of data at rest using industry-standard protocols (AES-256)
  • Secure authentication mechanisms and multi-factor authentication options
  • Regular security testing, vulnerability assessments, and penetration testing
  • Intrusion detection and prevention systems
  • Secure coding practices and code reviews
  • DDoS protection and mitigation

Administrative Safeguards

  • Role-based access controls limiting employee access to data
  • Background checks for employees with access to sensitive systems
  • Regular security training and awareness programs
  • Incident response and breach notification procedures
  • Data classification and handling policies

Physical Safeguards

  • Data centers with 24/7 security monitoring and access controls
  • Environmental controls to protect hardware infrastructure
  • Redundant systems and backup procedures
  • Disaster recovery and business continuity plans

While we implement robust security measures, no system is completely secure. We cannot guarantee the absolute security of your information, and you use the Services at your own risk. If you become aware of any security vulnerability or unauthorized access to your account, please contact us immediately at privacy@sequel.co.

Data Retention

We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Active Accounts

While your account is active, we retain all portfolio data, documents, and account information to provide the Tool's functionality.

Closed Accounts

If you close your account, we will:

  • Delete your personal information within 90 days, unless we are required to retain it for legal, regulatory, tax, or accounting purposes
  • Retain anonymized, aggregated data that cannot identify you

We may retain certain information longer when required by law.

Backup and Archival

Information may persist in backup or archival systems for a limited time after deletion from production systems, but these backups are not accessible for operational purposes and are securely destroyed according to our retention schedules.

You may request deletion of your information at any time by contacting us at privacy@sequel.co. We will honor your request subject to legal and regulatory obligations.

Your Rights and Choices

Depending on your location and applicable law, you may have certain rights regarding your personal information.

Access and Portability Rights

You have the right to:

  • Access the personal information we hold about you
  • Receive a copy of your data in a structured, commonly used, machine-readable format (data portability)
  • Export your portfolio data and documents from the Services at any time

Correction and Update Rights

You have the right to:

  • Correct inaccurate or incomplete personal information
  • Update your account information, preferences, and settings
  • Edit or modify your portfolio data and investment records

Deletion Rights

You have the right to:

  • Request deletion of your personal information (subject to legal exceptions)
  • Close your account and have your data removed
  • Delete specific investments or documents from your portfolio

Restriction and Objection Rights

You have the right to:

  • Restrict or object to certain processing of your information
  • Opt out of marketing communications (though we only send these with your consent)
  • Object to automated decision-making or profiling (if applicable)

Consent Withdrawal

Where we rely on your consent to process your information, you have the right to withdraw that consent at any time. This does not affect the lawfulness of processing based on consent before withdrawal.

Exercising Your Rights

To exercise any of these rights, please contact us at privacy@sequel.co. We will respond to your request within the timeframes required by applicable law.

Technology and Tools We Use

Sable relies on various third-party services and technologies to provide functionality. Below are the key tools we use:

  1. Cloud Infrastructure: We use secure cloud hosting providers (such as Google Cloud) to store data and run the Tool. These providers maintain SOC 2 Type II compliance and robust security certifications.
  2. Data Encryption: All data is encrypted in transit using TLS 1.3 and at rest using AES-256 encryption standards.
  3. Analytics and Monitoring: We use analytics platforms (such as Amplitude or similar services) to understand how users interact with the Tool, identify issues, and improve functionality. We configure these services to minimize data collection and respect your privacy.
  4. Error Tracking: We use error monitoring tools (such as Sentry) to identify and fix bugs and crashes. These services receive minimal technical data necessary for debugging.
  5. Customer Communication: We use email service providers and customer support platforms to communicate with you and provide support.
  6. Security Services: We use DDoS protection, web application firewalls, and security monitoring services to protect the Tool from attacks and unauthorized access.
  7. Backup Services: We maintain encrypted backups of your data to protect against data loss and ensure business continuity.

Each third-party service is carefully evaluated for security and privacy practices, and we enter into appropriate data processing agreements to protect your information.

International Data Transfers

The Tool is operated from the United States. If you are located outside the United States, please be aware that information we collect will be transferred to, processed, and stored in the United States and potentially other countries where our service providers operate.

These countries may have data protection laws that differ from those in your country of residence. By using the Tool, you consent to the transfer of your information to the United States and other countries.

For users in the European Economic Area (EEA), United Kingdom, and Switzerland, we rely on appropriate transfer mechanisms such as:

  • Standard Contractual Clauses approved by the European Commission
  • Adequacy decisions recognizing certain countries as providing adequate data protection
  • Other legally recognized transfer mechanisms

We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy regardless of where it is processed.

Specific Regulatory Compliance

SEC and Securities Regulations

We do not provide investment advice or broker-dealer services through the Services. The Services are solely for portfolio organization and tracking purposes. However, we maintain information security practices consistent with SEC guidance on cybersecurity and data protection.

We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

GDPR (European Users)

For users in the European Economic Area, United Kingdom, and Switzerland, we process personal data in accordance with the General Data Protection Regulation (GDPR) and UK GDPR.

Legal Basis for Processing

We process your personal information based on the following legal grounds:

  • Contract: Processing is necessary to provide the Tool and perform our contract with you
  • Legitimate Interests: We have a legitimate interest in improving the Tool, preventing fraud, and ensuring security (balanced against your rights and interests)
  • Consent: For certain processing activities, we obtain your explicit consent (e.g., marketing communications)
  • Legal Obligation: Processing is necessary to comply with legal or regulatory requirements

Data Protection Officer

For questions about how we process your data under GDPR, you may contact our Data Protection Officer at legal@sequel.co.

Children's Privacy

The Angel Portfolio Tool is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will promptly delete that information.

If you believe we may have collected information from a child, please contact us at privacy@sequel.co.

Third-Party Services

This Privacy Policy does not apply to third-party websites or services. We encourage you to review the privacy policies of any third-party services you access through the Services.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

When we make changes, we will:

  • Update the "Last updated" date at the top of this Privacy Policy
  • Post the revised Privacy Policy on our website and in the Tool
  • Notify you of material changes through email, in-app notification, or other prominent notice

Your continued use of the Services after the effective date of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the changes, you should discontinue use of the Services and contact us to close your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at privacy@sequel.co.