Nicco Privacy Policy

Last Updated: September 9, 2026 Effective Date: September 9, 2026 Applies to: niccohq.com and the Nicco service

Introduction and Scope

This Privacy Policy (“Policy”) explains how Nicco HQ Inc. (“Nicco,” “we,” “us,” or “our”) collects, uses, discloses, protects, retains, and otherwise processes Personal Data in connection with Nicco, including niccohq.com, Nicco's email-based services, workspaces, relationship intelligence and matching features, AI-assisted features, and related services (collectively, the “Service”).

This Policy applies when you use the Service, communicate with Nicco, provide information to Nicco, or when information about you is provided to Nicco by a Customer, another User, or a source described below. It also explains how Nicco handles information about people who are not Nicco Users, how the Shared Graph works, and the circumstances in which information may move between Nicco and a Customer such as Incolo.

A Customer's own privacy notice governs that Customer's independent processing of information it receives or controls. Nicco's legal role may differ by processing purpose, including between a private Customer workspace and Nicco's Shared Graph. Those roles are addressed through the applicable Customer agreement and are flagged below for counsel where they still require legal classification.

Definitions

For purposes of this Policy:

• “Customer” means an organization that has an agreement with Nicco to use or make the Service available for its founders, employees, members, portfolio companies, community, or other authorized participants. Incolo is currently a Customer.
• “User” means an individual who has accepted the Nicco Terms of Service and is authorized to use the Service.
• “Workspace” means a private area of the Service associated with a company, organization, project, raise, search, or other permitted purpose and accessible only to authorized Users.
• “Shared Graph” means Nicco's non-public relationship and matching layer that can use authorized professional facts and connection facts to identify possible paths between people and organizations. It is not a publicly browsable directory.
• “Personal Data” means information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual, as defined by applicable law.
• “Professional Information” means information relating to a person's professional identity or role, such as name, employer, job title, professional profile, company affiliation, and professional relationships.
• “Private Contact Details” means an individual's email address, telephone number, and other non-public means of directly contacting that individual.
• “Incolo” means LiveVested, LLC, which operates as Incolo, and, where the context requires, an affiliated Incolo entity acting in its own capacity as a Customer of Nicco.

The short version

• Nicco sees only what you copy it on, forward to it, send to it, or what an authorized Customer sends to Nicco under a specific data-sharing agreement. Nicco never connects to your mailbox.
• The fact that you know someone and limited public professional fields can help Nicco find paths for other users when the applicable sharing choice allows it. Email addresses and phone numbers do not feed the Shared Graph.
• A person appearing in an email does not enter the Shared Graph merely because Nicco saw the message.
• People who are not Nicco Users do not get a public profile because you know them.
• A conversation you record and send stays between you and the people you copied. Your own words in it are yours to share; the other person's are theirs.
• Nicco does not sell your data and does not train AI models on it.
• You can export your data and ask for it to be deleted, subject to the limited records Nicco must retain as described below.

1. Personal Data We Collect

From you directly: your name, email address, company, your public professional profile URL, and your role. Any additional email address you add, verified from that address, and what you say it is for. Your answers to the questions Nicco asks you by email.

From a Customer, including Incolo: a Customer may provide information to Nicco only under the Customer's agreement with Nicco and the authorization or other legal basis applicable to that person and purpose. For an Incolo founder who signed a Launch / RaiseQB agreement containing the specific Nicco data- sharing clause, the intended onboarding slice is limited to company name, founder name(s), founder email address(es), LinkedIn URL(s) if supplied, and the company’s LinkedIn URL if supplied. Nicco records the source event and provenance of that transfer. The transfer does not by itself make the person a Nicco User. Where applicable law requires Nicco to provide a notice or obtain an additional authorization for information received indirectly, Nicco will do so as required.

From emails you copy Nicco on, or forward to it: the sender, recipients and CC list, the subject, the body, and any attachments. Nicco records who was on the message so it knows who is entitled to see it. When you forward emails from your own history, Nicco files only the ones you were a party to and records that you forwarded them.

From recorded conversations you send: the statements each speaker made, each tied to the exact words it came from, and the names of people mentioned.

From connection exports you send: for each connection, their name, employer, job title, public profile URL, the date you connected, and — only where the export contains it — an email address. In practice fewer than 3% of rows carry one, because the source only includes it when that person opted in.

If you ask Nicco to help with a raise, or with a list of customers or partners: the organizations you want to reach, where each one stands, who owes the next move and what it is, the paths tried and what came of them. Nicco adds to it from what you send and from what it finds. This is your own working record; Nicco keeps it so it can tell you who can reach each target and why, and it is seen only inside your workspace, by you and the people you have invited to help.

People you invite to help: their name and email address, their agreement to the terms (which each gives for themselves), their role in your workspace, and what they do there. Their own connections and material stay theirs.

From public sources: professional information already public about the organizations and people in your material — a company's website, a public profile, a press release — used to name an organization correctly or to check a role. A person at Nicco confirms each such finding before Nicco relies on it, and the source is recorded with it. Nicco does not buy data about anyone.

From the website: Nicco does not use advertising cookies, analytics, or session-recording tools. Its hosting and security infrastructure may generate basic technical logs needed to deliver and protect the service. If that changes materially, this policy changes first.

2. How We Use Personal Data and Our Legal Bases

Where applicable law requires Nicco to identify a legal basis for processing, Nicco relies on the basis appropriate to the particular purpose:

Where Nicco sends replies

Nicco answers the address a message came from, and only addresses you have verified as yours. Whoever controls that mailbox, for example an employer or a mail administrator, can read what Nicco sends there. Choosing which address to write from is your choice of channel. When you add an address, Nicco records that choice and the purpose you gave, so that "why did this land there" has an answer. Nicco never sends another person's Private Contact Details to any address; see section 3.

Marketing and advertising: none. Nicco sends no marketing messages and shares nothing with advertising platforms; your email address and phone number are not used to build audiences anywhere. The only messages Nicco sends unprompted are the two described next.

Nicco almost always writes in reply. Two exceptions: a short reminder at the bottom of an ordinary reply, at most once a week, asking for your connections file if you have not sent one; and, during the beta, an occasional message from Nicco's address when a person at Nicco has found someone worth reconnecting with from a conversation you sent — "the call you had with X a few weeks ago; here is someone in your network, or in another member's, who fits". Reply "unsubscribe" or "stop emailing me" and neither happens again; Nicco records that and will only ever answer messages you send it after that.

3. Information About People Who Are Not Nicco Users

This is the part that deserves your attention, because those people did not choose to be here.

When you share your network, Nicco holds information about people who have no account. Nicco applies a hard split, enforced by two independent mechanisms in the database rather than by policy alone:

May help Nicco find paths for Nicco Users you have chosen to share with: the fact that you know them, their employer, their job title, when you connected, and their public professional profile URL — limited professional information, where the applicable source and sharing authorization permit that use.

Does not feed the Shared Graph and is not exposed across accounts by default: their email address, their phone number, and any private note you wrote about them. A private contact detail is disclosed to another user only through an introduction / mutual-opt-in flow or another explicit authorization by the person whose contact detail it is.

Additionally:

• Source matters. A person appearing in a connections export may contribute a limited connection fact if you chose the applicable sharing setting. A sender, recipient or CC'd person does not enter the Shared Graph merely because their identity appeared in an email. Email-derived identity stays internal / workspace-scoped unless a later authorization or separately recorded public-professional source permits broader use.
• They are not added to any public or shared directory. Knowing someone does not create a profile of them that other users can browse.
• You can ask Nicco to exclude a particular person from ever being surfaced through you; the exclusion holds over every sharing setting and survives a re-upload. To exclude someone, write to Nicco: "exclude" followed by their email address, their LinkedIn profile, or their name as it appears in your connections.
• A person can ask what Nicco holds about them and ask for it to be removed. See section 8.

People on your target list

An investor, a fund, a company or a person you want to reach is on your list because you put them there or because Nicco found a path to them. Nicco holds their name, organization, public role, where they stand in your process, and what you recorded about them. It uses that to find and explain paths and shows it inside your workspace. Nicco never contacts them; you, or a person who can introduce you, do. Like anyone else who is not a user, they can ask what Nicco holds about them (section 8).

People on a recorded conversation

When you send a transcript, Nicco holds statements made by and about the people on that call, most of whom are not Nicco Users.

• What Nicco requires of the person who sent it: Nicco accepts a transcript only on that User's confirmation that they had the consent they needed to record the conversation and to share it with Nicco. Nicco is not present for the conversation and cannot verify that confirmation. If you were recorded and believe it was wrong, write to privacy@niccohq.com and say so; Nicco will act on it.
• Who can read it: you, and the people you copied on the email that carried it. Nobody else, and no setting of yours changes that.
• Whose words can be shared more widely: each speaker's own, only by that speaker. If the other person is not a Nicco User, their words cannot be shared at all; they can still inform which introductions Nicco suggests to people who may read them, and are never repeated to anyone who may not.
• People who were not on the call: Nicco records that they were named and what was said they do, and does not record negative statements about them.
• Introduction asks: if you ask Nicco to, it tells another Nicco User the name and public professional profile of a person you spoke with, and a few sentences on what that person is doing from your conversation, to ask whether they are open to an introduction. Nothing about that person goes to anyone who does not have a Nicco account.

The Shared Graph

Nicco's Shared Graph is a non-public matching layer. It is used to answer questions such as whether one member can reach a professional target through another member; it is not a directory of everyone Nicco knows about.

A permission is field- and purpose-specific. Permission for Incolo or another Customer to see a record does not automatically permit shared-graph use, and shared-graph permission does not permit Nicco to expose a private email address. For an Incolo-onboarded founder whose applicable Launch / RaiseQB agreement expressly authorizes the Nicco shared-graph use, the eligible fields are company name, founder name, LinkedIn URL and company LinkedIn URL. Founder email may be transferred to Nicco as part of the five-field onboarding slice for identity / account purposes but is excluded from the Shared Graph unless that person separately opts into system-wide email exposure.

Customer-specific records — a fundraising pipeline, notes, interactions, private investor intelligence, advisory or investment relationships, CU records and similar context — remain private to the applicable Customer / workspace and do not contribute to the Shared Graph.

Nicco and Incolo

Nicco HQ Inc. operates the Nicco platform. LiveVested, LLC operates as Incolo, owns Nicco HQ Inc., and can also be a Customer of Nicco. Corporate ownership does not itself give Incolo access to Nicco-direct data.

• Nicco to Incolo: a person who joined Nicco directly is not made visible to Incolo merely because the companies are affiliated. Nicco shares Nicco-direct information with Incolo only where the person separately opts in or another clearly documented legal basis applies.

Nicco's legal role in processing information may differ by purpose and is governed by the applicable Customer and data-processing agreements.

4. How Nicco Handles and Shares Information

• Nicco receives what you copy it on, forward to it, or send it. It has no connection to your mailbox, so tax documents, cap tables and agreements that sit in a real inbox are not something it can see unless you send them.
• Nicco uses your material to find and explain introduction paths, to reply to you, and to improve how well it does those things. A field leaves its workspace or contributes to the Shared Graph only where an applicable authorization or other recorded legal basis permits that purpose. Nicco does not sell personal data.
• Your content is processed by Nicco's AI providers under commercial terms that exclude training on it; Nicco does not train models on your content.
• A person's Private Contact Details do not feed the Shared Graph. They move between accounts only when the applicable introduction / opt-in rule permits it or the person has separately authorized that broader exposure.

5. Service Providers and Other Recipients

Voyage AI's default terms let it keep and train on content sent to its API; Nicco has opted out, so content Nicco sends to Voyage AI is used only to compute the vector and is not retained (Voyage AI calls this zero-day retention). The vectors themselves are stored in Nicco's own database.

Anthropic does not train on data submitted through its API. Content Nicco sends to Anthropic to produce a reply or a suggestion is held by Anthropic for the time its applicable commercial terms permit and, where Nicco uses prompt caching, for the cache's lifetime. Nicco's memory tool stores nothing with Anthropic because the store is Nicco's own database.

During the beta, Nicco personnel also work with customer material inside interactive Claude sessions (Anthropic's Claude Code, under Anthropic's commercial terms, which exclude training on customer content) to do by hand what the software does not yet do on its own: confirming organizations and roles, deciding which suggested paths are worth a person's time, keeping a raise pipeline current, and preparing the occasional follow-up described in section 2. The same confidentiality obligations and the same access rules apply as for any other staff access.

Nicco uses contractual and data-protection safeguards with service providers where required by applicable law.

International transfers

Nicco is a U.S. company and the providers above may process data in the United States or other countries where they operate. Where applicable law requires a specific mechanism for an international transfer of Personal Data, Nicco uses an appropriate lawful transfer mechanism.

Nicco personnel

People who work on Nicco can access customer material when they need to. Today that is one person, Nicco's founder; any contractor who later works on Nicco gets access only under the confidentiality agreement below. In practice that means building and fixing the system, investigating a problem you have reported, reviewing how well the matching works, watching Nicco's own conversations for abuse and for attempts to extract what it holds about other people, and — during the beta — doing parts of Nicco's work by hand: reading a conversation you sent to find who in your network or another member's it points to, confirming an organization or a role from a public source, keeping the raise pipeline you asked for help with, and sending the occasional follow-up from Nicco's own address. Every one of those is the same work the software is being built to do, applied to the same material you already gave Nicco for that purpose, and nothing found that way is shared more widely than the software's own rules allow.

One thing bounds it:

• Everyone with this access is under a written confidentiality agreement before they get it.

6. Artificial Intelligence and Automated Processing

Nicco uses AI to categorize incoming email, draft replies, read recorded conversations into statements, and suggest introductions.

Three safeguards are built in:

1. Every extraction must quote its source. If the AI cannot point at the exact sentence it drew a statement from, the software discards the statement automatically.
2. AI output is a suggestion, not a fact. Extracted statements are marked as proposals. Nicco uses them to suggest introductions to you and to the person who sent the conversation, and each suggestion cites the statements it rests on; Nicco does not suggest what it cannot cite. Nothing is shared more widely or added to the Shared Graph on a proposal alone: the field also needs the authorization or other recorded legal basis required for that purpose. A reviewer may verify a public-source professional fact; a reviewer does not substitute for consent where consent is required.
3. Nicco records which information came from a model and which from a human, and what source text an extraction came from.

Nicco does not make decisions that produce legal effects about you. You may request human review of any automated decision that materially affects you.

7. Retention

Nicco archives rather than hard-deletes internally, so that removing one person's data does not corrupt records belonging to others. Archived data is excluded from all processing and access.

When you close your account or ask for deletion, your material is archived and excluded from every reader and every process at once, and removed on the schedule above. Three things remain: the record of what you agreed to and when; what other members already hold because you shared it with them or introduced them (an introduction someone made, a path someone acted on), which is theirs; and counts and measures that identify nobody. Nicco retains or deletes information subject to applicable law and the limited exceptions described above.

Customers and communities

If you use Nicco through a Customer, the Customer can see only the Customer- scoped information and other information that its agreement and your applicable choices permit. It does not receive blanket access to your Nicco account merely because it pays for or sponsors access. A Nicco-direct user is not visible to Incolo by default; sharing with Incolo requires the separate choice described above. The Customer's own privacy terms govern what it does with information it lawfully receives from Nicco.

If something goes wrong

If Nicco discovers a security incident that puts your data at real risk, it tells you without undue delay: what happened, what was affected, what Nicco has done, and what you can do. It also tells the authorities the law requires. Nicco provides legally required security-incident notices within the time and manner required by applicable law.

8. Your Privacy Rights

Depending on where you live and the law that applies, you may have rights concerning the Personal Data Nicco processes about you. Subject to applicable exceptions, you may access, correct, export, or delete your data, withdraw a consent or sharing authorization, and object to processing where the law gives that right. A permission can be withdrawn for a specific purpose — for example, shared-graph contribution or Nicco-to-Incolo sharing — without necessarily closing the whole account. Requests go to privacy@niccohq.com and Nicco will respond within 30 days. To stop Nicco writing to you first, reply "unsubscribe" to any message from it; that takes effect at once and is recorded. Withdrawal takes effect prospectively; it does not undo processing that lawfully happened before, and Nicco may keep a limited record of the prior authorization and withdrawal as evidence.

If you are not a Nicco User but believe Nicco holds information about you because someone in your network shared it or recorded a conversation with you: write to the same address. Nicco will tell you what is held and remove it on request, subject to applicable law and any lawful exception.

Where applicable law gives you the right to complain to a data-protection or privacy regulator, you may do so in addition to contacting Nicco directly.

9. Security

What is in place, stated as it is:

• Encryption. Data is encrypted in transit and at rest by Nicco and its infrastructure providers.
• Access controls. Access to private information is limited based on who is authorized to see it and the purpose for which it is being used. Making company information visible does not make private information about the people connected to that company visible. Email addresses and phone numbers do not feed the Shared Graph.
• Logging. Nicco's own automated reads across accounts are logged with what was read and why. Staff reads are not yet logged (section 5).
• Monitoring. Nicco's providers monitor their platforms around the clock. Nicco does not run its own 24/7 monitoring; it is alerted when its own mail pipeline fails, and it checks its own systems during working hours.
• Accounts. Access to Nicco's systems is through named accounts with its providers; Nicco's accounts are protected by multi-factor authentication.
• Audits. Nicco has not had a third-party security audit and does not claim one. Nicco tests its access controls as part of its development process.
• Classified and controlled information. Nicco is not certified, accredited or authorized to hold classified information, Controlled Unclassified Information (CUI), export-controlled technical data, or other information whose handling a law, a government or a contract restricts, and it does not monitor what members store for it. The Terms (section 4.8) ask members never to store it. When Nicco is told that it has been stored, Nicco deletes it, rather than archiving it as it does other data (section 7), from every account and space that holds it, and from its backups when their retention period ends. Nicco keeps a record that a deletion was made and when, without the deleted content.

10. Children's Privacy

Nicco is not for anyone under 18 and does not knowingly collect their data.

11. Changes to This Policy

Nicco may update this Policy as the Service, law, or Nicco's data practices change. Each revision is published as a new numbered version with a permanent record of its exact text. Material changes that require a new authorization or agreement will not be applied on the basis of silence or continued use alone; Nicco will obtain the agreement or authorization required for that change.

12. Contact

Questions about this Policy or requests concerning Personal Data may be sent to:

privacy@niccohq.com

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