1. Personal Information We Collect

We may collect Personal Information about you from various sources described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from the Service if that information is necessary to provide you with them or if we are legally required to collect that information.

1. 1.1 Information Provided by You

   1. Registration. You provide us Personal Information when you register to be a User:
      1. Your name;
      2. Your email address;
      3. Your username;
      4. Your password;
      5. Your Facebook information if you are signing up via Facebook connect (this will authenticate your identity and link your Facebook Profile information, such as your name, profile image, and email address, to your account);
      6. You may provide your location and a profile image.
   2. Investors. If you become an Investor, you may provide us with the following Personal Information in addition to the Personal Information you provide when you register to be a User:
      1. Your legal physical address;
      2. Your telephone number;
      3. Your date of birth;
      4. Your business name, address, email and phone number, names of owners and management, if applicable;
      5. Balance sheets, profit and loss statements, bank account information, average bank balance, bank statement and other financial data, including tax returns, as applicable, in order to help verify your “Accredited Investor” or "Qualified Purchaser" status;
      6. Tax ID number or social security number, as applicable, and citizenship status;
      7. Responses to further questions answered during the profile creation.
   3. Identity verification. You may be asked further information in order to help validate your identity:
      1. Your driver’s license information, government issued identification number;
      2. Other Personal Information as we need for verification;
   4. Messaging. The Site permits Users to communicate with other Users posting information on the Site. We may read, collect and analyze information transmitted between Users for regulatory compliance purposes. We do not guarantee that information provided by Site visitors is accurate or complete. We assume no liability or responsibility for any errors or omissions in the content of this site, other than as required by law.
   5. Communications. We may also collect Personal Information from you as a result of your email communications with us including your posts, our responses, the date and time of the inquiry and any other information you choose to submit to us.
   6. Transaction Information. We may collect details of any requests or transactions you make through the Service.
   7. Payment Information. All payment information you submit is collected and used by our payment processors in accordance with their privacy policies. We do not store your payment information apart from the last four digits of your account, expiration date, and country, which we require for tax, government regulatory, and security purposes.
   8. Business Partners. If you work for one of our business partners or vendors, we will collect your contact details to manage the business relationship.
   9. Job Application. If you apply for a job with us, we will collect your application information, including your resume and the contact details of your referees, as well as any other information you chose to provide to us in the context of your application.

2. 1.2 Information Collected via Automated Means

   1. Cookies. In addition to information that you provide to us, we may collect Personal Information about you and your use of the Service via automated means, such as cookies and similar technologies. This information may include your IP address or information about your interactions with the Service (e.g., where you clicked and which pages you visited).
   2. Location Information. When you use the Service via a mobile device, we may collect your location information, provided that you have authorized us to do so via the mobile device operating system.

3. 1.3 Information Provided by Third Parties

   1. Social Sign-On. You can sign up for or sign in to your account using Facebook Connect. When you sign in using Facebook Connect, we will receive the following information: your public profile and email address. We us this info to authenticate your identity and link your Facebook Profile information to your account. You can disconnect Facebook Connect by going to your Facebook app settings.
   2. Our Partners. We may obtain address information about you from third party and public sources, including Jumio-NetVerify, Blocksore and Computershare for fraud prevention, legal compliance or to provide the Services.

2. Use of Information

1. Purposes of the Processing. We may use your Personal Information in order to:
   1. operate and provide you with the Services, including to verify your identity and allow payment processing;
   2. communicate with you and respond to your inquiries, send you transaction and Service related emails;
   3. analyze your preferences, interests and behavior in order to provide you with tailored content and the most relevant content and communications;
   4. send you marketing communications;
   5. keep your account secure; protect our Site, Service and Users;
   6. analyze and improve our Site and the Service;
   7. to process your job application;
   8. manage our business relationships;
   9. enforce our Terms of Use, our legal rights and to comply with applicable law, a subpoena, or similar legal process or to protect against legal liability and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
   10. for other purposes for which we provide specific notice at the time of the collection of the information
2. Legal Ground for the Processing. Where required under applicable law, we will only collect and process Personal Information about you if we can rely on a valid legal ground for that processing, such as consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Service you have requested)), legal obligations (e.g. for compliance with securities laws) and “legitimate interests” (e.g. for product development and analytics purposes).

If you have any questions about the lawful bases upon which we collect and use your Personal Information, please contact us as described below.

3. Disclosure of Information

1. Entities. We may share Personal Information about you with our affiliates and subsidiaries.
2. Service Providers. We may share the information that you have provided us with certain trusted third-party services to help us provide, improve, promote, or protect the Services (including with payment processors, services to manage ads on other sites, and to analyze our Site’s functionality). Payment information you provide through our Site is processed directly through either Stripe or PayPal, as the case may be. We may provide such services with additional information that you have provided to us in order to help them or us verify the transaction.
3. Other Third Parties. As an Investor, we may share Personal Information about you with third parties, such as Jumio-NetVerify, Blockscore, FundAmerica, HelloSign, and Computershare, in order to verify your status with respect to securities laws, facilitate your payment and any escrow of funds, to record your investment with our third party SEC-registered transfer agent and provide you with necessary tax reporting information.
   We may also share information that is aggregated and anonymized in a way so that it does not directly identify you.
   We do not and will not sell any of your Personal Information to any third party for purposes of advertising, soliciting, or telemarketing. We may, however, disclose your Personal Information to other companies or entities as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock. In that case your Personal Information may be sold or transferred to the potential or actual acquirer, successor, or assign.

4. Your Rights and Choices

1. Marketing. We may at times send you email communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional emails from us, you may unsubscribe completely by contacting us using our contact form on [email protected] or you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails.
   Please note that opt-out requests may take up to one week to process. Please also note that at times we may need to send you email communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.
2. Location Information. Most mobile devices allow you to control or disable location services in the device’s setting’s menu. If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device.
3. Other choices. You are able to access, update and modify the information concerning your account by visiting your Profile page and editing any information in your Profile. You are able to change your email address, password, contact information, privacy settings or other login information by visiting your account’s settings page. If you wish to suspend your account or need help modifying account information, including changing your status as an “Accredited Investor” or "Qualified Purchaser", please contact us using our contact form on [email protected].
   If you would like us to remove, or provide additional access to, any Personal Information from our database, please send a request via our contact form on [email protected] and we will do so or you will receive a response within one month.
4. European Users. If you are located in the European Economic Area or Switzerland, you may have the right to:
   1. Request access to and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or to object to the processing of your Personal Information, to have the information anonymized or deleted, as appropriate, or to exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
   2. Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
5. Those rights may be limited in some circumstances by local law requirements. You may exercise your rights by contacting us as specified below.

5. Data Transfers

Since we are based in the United States, your Personal Information will be collected and processed in the United States. The United States has its own laws governing data protection and government access to information. The rules that protect your personal information under United States law may be different than in your home country.

6. Links to Other Websites, Blogs/Forums and Social Media Widgets

Our Site includes links to other websites whose privacy practices may differ from ours. When you use a link to go from our Site to another website, such as that of our payments processors, the privacy statement for the other website governs. We encourage you to carefully read and understand the privacy statement of any website you visit.

Our Site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be displayed publicly and read, collected, and used by others who access them. To request removal of your Personal Information from our blog, contact us at [email protected]. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.

Our Site includes social media features, such as the Facebook “Follow Us” button, and widgets, such as the “Share This” button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

7. Security and Data Retention

1. Security. The security of your Personal Information is important to us. We follow generally accepted standards and have implemented security measures we believe to be appropriate in order to protect the Personal Information we collect, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is completely secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at [email protected].
   We use Security Sockets Layer (SSL) encryption technology to encrypt Personal Information (such as your payment information) before it travels over the internet. Credit card numbers are never stored on our database or servers.
   It is important for you to protect against unauthorized access to your password and to your computer. Be sure to log off when finished using a shared computer.
   We will promptly notify those persons whose Personal Information is compromised. Notwithstanding, we do not accept liability for any unintentional disclosure or a disclosure that occurs due to a security breach of our systems or facilities.
2. Data Retention. When determining the retention periods, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

8. Children’s Privacy Policy

The Site is not intended for use by children. No one under eighteen (18) years of age is allowed to use the Site, provide any Personal Information or receive our email distributions. We do not knowingly solicit or collect Personal Information from anyone under eighteen (18) years of age. If you believe that a minor has disclosed personally identifiable information to us, please report this to us immediately by contacting us via our contact form on [email protected].

9. Changes to This Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to our Site. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on our Site prior to the change becoming effective. You can determine if changes have been made by checking the effective date below. Your continued use of our Site following the posting of any changes to this Privacy Policy means you accept such changes.

10. English Language

The English version of this Privacy Policy governs. All disputes, claims and causes of action (and related proceedings) will be communicated in English.

11. Contact Us

We are the entity responsible for the processing of your Personal Information. If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this Site, please contact us at [email protected] or at 335 Madison Avenue, 16th Floor, New York, NY 10017.

This Privacy Policy was last updated on Jun 18, 2020.