This Policy does not cover the personal information we collect about employees and independent contractors, or job applicants.
Notice at Collection: Personal Information We Collect
We collect the following categories of personal information:
- name, email address, your home or billing address, telephone numbers, online identifier, account name and password, information related to reviews, IP address, government identifiers
- purchasing or consuming histories; and investor information
- your device and browser type, your browsing and search history on our website, and information regarding your interaction with our website
- job title, information about your employer
- government identifiers
Notice at Collection: Purposes for Collection of Personal Information
We collect your personal information to provide our services to you and fulfill investment requests; to contact you from time to time; to provide you with information about our business; for investor support; offers about opportunities we think may be of interest to you; to respond to your inquiries; and to customize your experience.
For those who interact with us in a commercial capacity, we use your personal information to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent.
Notice at Collection: Categories of Personal Information We Sell or Share and Related Information
We do not sell personal information or share personal information for purposes of cross-context behavioral advertising.
Notice at Collection: Retention Periods
We retain the categories of personal information we collect for the length of time necessary to provide our Services and to comply with legal obligations or to protect our legal rights.
Sources From Which We Collect Personal Information
We collect personal information directly from our investors, website users, and representatives of entities with which we do business or may do business. We also collect personal information from data aggregators and data brokers.
Use or Disclosure of Sensitive Personal Information for Inferring Characteristics
We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services.
Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of personal information we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:
|Categories of Consumers’ Personal Information
|Categories of Third Parties to Which We Disclosed Personal Information for Business Purposes
|Personal identifiers:name,email address, your home or billing address, telephone numbers, online identifier, account name and password, IP address, government identifiers
|Service providers that process investments, verify investor information, manage investor information and provide investor services (including through our call center and chat features), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytics information, and provide legal and accounting services.
|Protected class information: age, race, sex/gender identification, ethnicity, military or veteran status
|Service providers that process investments, verify investor information, manage investor information and provide investor services (including through our call center), provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, and provide analytics information.
|Commercial and financial information: Purchasing or consuming histories; and investor information
|Service providers that process investments, verify investor information, manage investor information and provide investor services (including through our call center and chat features), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytics information, and provide accounting services.
|Internet or other electronic activity information:your device and browser type, your browsing and search history on our website, and information regarding your interaction with our website.
|Service providers that provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, and provide analytics information.
|Professional information: job title, information about your employer
|Service providers that manage vendor relationships.
|Sensitive personal information: government identifiers, including driver’s license information
|Service providers that help us manage investments.
Business Purposes for Such Disclosures
We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to manage investor, supplier and vendor accounts and relationships; process investments; verify investors’ identities; fulfill investment opportunities; operate our IT systems and secure our systems; prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.
Additional Information About How We May Disclose Personal Information and Purposes for Disclosures
We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.
Personal Information of Minors
Our products and website are not directed to minors under the age of 13 and we do not knowingly sell or share for purposes of behavioral advertising the personal information of minors, including minors under 16 years of age.
Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.
Third Party Websites
How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
Changes to This Policy
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at firstname.lastname@example.org.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, the California Consumer Privacy Act (“CCPA”) and other laws provide you with the following rights with respect to your personal information:
Your Right To Know About Personal Information We Collect
You can ask us for the following information from us with respect to the personal information we have collected about you since January 1, 2022:
- Specific pieces of personal information we have collected about you;
- Categories of personal information we have collected about you;
- Categories of sources from which such personal information was collected;
- Categories of personal information that the business disclosed for a business purpose about the investor;
- Categories of third parties to whom the personal information was disclosed for a business purpose; and
- The business or commercial purpose for collecting your personal information.
Your Right To Request Deletion of Personal Information We Have Collected From You
Upon your request and subject to exceptions in the law, we will delete the personal information we have collected from you.
Your Right to Request to Correct Personal Information We Hold About You
You have the right to request that we correct personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct to assist us in evaluating the request.
Our Commitment to Honoring Your Rights
Exercising Your Rights and How We Will Respond
To exercise your rights to know, delete or correct your personal information, or to ask a question, contact us at email@example.com. For such requests, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Verification of Identity – Requests to Know, Delete or Correct
We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity.
- Requests to Know, Delete or Correct Personal Information: If the agent submits a request, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.