Republic Core Privacy Policy

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 You Provide to Us

   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(s);
      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.
      7. Citizenship and residency information.
   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”, “Qualified Client”, "Qualified Purchaser" or “Non-U.S. Person” 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 or other 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

   As you navigate through and interact with our Site and use the Service, we may use automatic data collection technologies to collect certain information. This information helps us address customer support issues, improve the performance of our Site and Service, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

   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 authentication data, browser fingerprint, operating system, your IP address or information about your interactions with the Service (e.g., where you clicked and which pages you visited). Cookies are small text files containing strings of alphanumeric characters that may uniquely identify your browser and let us help you log in faster and enhance your navigation through the Site. A cookie may also convey information to us about how you use the Services (e.g., the pages you view, the links you click, how frequently you access the Services, and other actions you take on the Services), allow us to track your usage of the Services over time, and help us remember information about your visit. You can set your browser to not accept cookies, but this may limit your ability to use the Services. Our Site uses the following types of cookies:
      • Essential Cookies: These cookies are necessary to provide you with the Services available through the Site.
      • Performance and Functionality Cookies: These cookies are used to enhance the performance and functionality of the Site.
      • Analytics and Customization Cookies: These cookies collect information that is used either in aggregate form to help us understand how the Site is being used or how effective our marketing campaigns are, or customize the Site for you.
      • Advertising Cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interest.
      • Social Networking Cookies: These cookies are used to enable you to share pages and content that you find interesting on our website through third party social networking and other websites. These cookies may also be used for advertising purposes.
      This Privacy Policy does not cover the collection of information by cookies or other methods by third-parties. Please see How to Remove Cookie Tracking below for details on how to disable cookie tracking.
   2. Web Beacons. Web beacons or tracking pixels or clear gifs are another tool we employ. A tracking pixel is a transparent graphic image that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the web page that contains the tracking pixel. We use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our website. We also use them to tell when an advertisement we run on another website has been clicked on by Republic visitors and use that information to judge which advertisements are more appealing to users.
      Tracking pixels can also be used for third party web analytics and are used in HTML-based emails we send you to track which emails are opened and which links you click. The information collected from web beacons allows for more accurate reporting and improvement of the Services.
      Although we do our best to honor your privacy preferences, we are not able to respond to “Do Not Track” signals from your browser or device at this time.
   3. 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 use 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 but not limited to Jumio-NetVerify, Blockscore, BitPay, Securitize 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 and other messages;
   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, regulation, 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 Prime Trust’s API, Stripe, BitPay or PayPalPlaid, 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. We may add additional payment processing services to the Site and by using such services, you may be bound to their terms of service, privacy policies and any necessary data sharing to facilitate such services.
3. Professional Advisors. We may share Personal Information with third party professional advisors who provide banking, legal, compliance, insurance, accounting, fund administration or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
4. With Law Enforcement, Officials, or in Legal Proceedings. We may share Personal Information when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Service or any other applicable policies.
5. Republic Note Wallet Service Providers. If you are a Republic Note holder, we may share certain Personal Information with Comakery in connection with setting up your Republic Note Wallet (as defined in th Terms of Service) and when you need to reset your private key seed codes for your Republic Note Wallet. This includes your name, accredited investor status, and transfer restrictions associated with your investment based on U.S. securities laws. As part of the seed code reset process, your name and login information will be shared with Aikon. Please view the privacy policies of Comakery and Aikon, Please note these privacy policies are subject to amendment at Comakery and Aikon’s sole discretion.
6. 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 and anti money laundering 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 assigns.

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 or by configuring your preferences at https://republic.co/settings/notifications.
   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, Switzerland, or the United Kingdom, 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, including when: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons. You may exercise your rights by contacting us as specified below.

5. How To Remove Cookie Tracking

We use tools, such as Google Analytics, to facilitate the collection of information. If you wish to disable Google Analytics from all websites you visit (not limited to our website), you can follow this link. The information gathered through the tools we employ is used to create reports about the use of our website and Services.

6. 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. For European Economic Area, or Switzerland, or the United Kingdom Users, if transfers of personal information are processed in the US, we may in some cases rely on Article 49 of the GDPR.

7. 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.

8. 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.
   Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account. 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. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in this Privacy Policy.
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. Information about our typical retention periods for different aspects of your personal information are described below.
   • Personal information collected to comply with our legal obligations may be retained after account closure for as long as required under such laws.
   • Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
   • Content that you post on our Site such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).
   • Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
   • Information about the transactions you enter into with other users of the Services when using the Services may be held even after account closure.

9. 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].

10. 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.

11. 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.

12. 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 April 12, 2021.