Last Updated: December 21 2020
We may collect personal information from you in a variety of ways, including the following key categories and types of personal information:
● Contact information: Name, alias, email address and phone number.
● Financial information: Information about your financial profile, net worth, current portfolio allocation, investment interests and experience with and intent to make investments in private securities. If you are an investment professional, we may also collect information about your employer, including corporate information and investment profile and strategy, the identity or characteristics of your clients and investors, and any other information you provide on our request.
● Professional or employment-related information: Professional and employment information shared by you, including your position and employer and educational experience.
● Geolocation data: The general region or area from which you access our Services.
● Internet or other online activity: Referral channels that led you to our Services, browsing and click history and information about how you navigate our Services.
● Inferences: We may make inferences based on the information we collect, including information about your experience and sophistication as an investor.
● Information from public sources. We may obtain information about you and (if applicable) your employer on the internet or through offline sources and other public or commercial sources.
How We Use Collected Information
We may collect and use your personal information for the following purposes:
● To provide and improve customer service. We use your contact information, employment-related information and various inferences described above to answer your questions and respond to your requests and enquiries, provide you the Services and improve and maintain functionality of our Services.
● For analytical purposes. We use your internet activity, browsing history and geolocation data to analyze preferences, trends and statistics. We may also use your activity on our Services in an anonymized and aggregate way in order to improve our Services. We may also use your information to protect the Company, our Services and our website, and to prevent fraud, theft and misconduct.
● For relevant updates, marketing and promotional purposes. We use your contact information, employment-related information and various inferences described above to send you relevant, articles, blog posts, newsletters, podcasts and other information we think may be relevant to you. We may also use information about your use of our Services in an anonymized and aggregate way to analyze trends and statistics and to promote and market our Services.
How We Collect Your Personal Information
We collect personal information from the following sources:
● Passively. We and our service providers collect personal information from you passively from the internet and other automatic data collection tools, such as cookies and web beacons, which are summarized below:
o Web Beacons
. Pages of our website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
o Tracking Tools
. We use the following tracking tools:
▪ Google Analytics and Adwords:
We use Google tools such as Google Analytics and Google Adwords to understand how users use our website. This includes looking at where a visitor comes from and where they go when they leave our site. Google Analytics provides an opt-out for its tool here
▪ Other tracking tools: We may deploy other automatic tracking tools in the future. Similar to the tools we currently use, such future tracking tools will track data about our visitors only in the aggregate and on an anonymized basis and will not reveal personal information about you.
When We Share Your Personal Information with Third Parties
● With service providers who do things on our behalf. For example, we will share information with vendors and contractors who conduct email marketing for us or who assist us with developing and providing the Services and customer support. Such service providers may reside outside the United States and in countries that may not provide the same level of protections as the laws of the United States.
● With investment professionals for promotional and other purposes in connection with the Services. We may use your information to share reports and statistics with investment professionals to promote our Services. Information shared for such purpose shall be anonymized and aggregated.
● With partners for research and data purposes in connection with developing and improving the Services. We may share your information with third-party partners who help us in developing and improving the Services. Information shared for such purpose shall be anonymized and the third parties in which we share such information shall be subject to non-disclosure obligations.
● With third parties as directed by you or to support transactions you engage in via the Services. We may share your information with third parties with your consent or as requested by you, or in connection with a transaction you engage in through the Services.
● In accordance with applicable law. We may share your information with the appropriate authorities if we believe disclosure is in accordance with, or required by, any applicable law, including lawful requests by public authorities to meet national security or law enforcement requirements.
● In connection with sale of the Company. In the event of a reorganization, merger, or sale we may transfer your personal information we collect to the relevant third party.
We Do Not Sell Your Personal Information
We do not sell, trade, or rent your personal information to others.
Third-Party Links and Websites
Our Services may contain advertising, links or other content from the websites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties (collectively, the “Third-Party Services”). We do not control the content or links that appear on these Third-Party Services and are not responsible for the practices employed by such Third-Party Services. In addition, these Third-Party Services may have their own privacy policies and customer service policies. Browsing and interacting on any of these Third-Party Services are subject to such Third-Party Services’ own terms and policies.
Our Content on Third-Party Services
You have certain choices on how we treat your personal information, described below:
● Modifications to Personal Information
You may review and request modifications to your personal information by editing your profile directly on our website or by contacting us at email@example.com
. Please note that we will retain data for as long as it is reasonably necessary to fulfill the purpose for which it has been collected or as required or permitted by applicable law. If you provide us with updated information, we will do our best to keep your information accurate and up-to-date. We will make good-faith efforts to make requested changes in any active database as soon as practicable.
● Marketing Communications
. You can opt out of promotional marketing emails by contacting us at firstname.lastname@example.org
. We may give choices about other emails and communications you receive from us. If you opt-out, we may still send you non-promotional communications, such as those about your account or our ongoing business.
● Ad Choices.
. If you would like to opt-out of such ad networks’ and services’ advertising practices, go to www.aboutads.info/choices to opt out in desktop and mobile web browsers. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile applications.
● Tracking Technology. You may turn off part or all of our tracking software that has been placed on your computer by following the instructions on your browser. On a mobile device, you may turn off part or all of mobile tracking through your mobile device settings. However, if you prevent the use of tracking software or tracking through your mobile device, it will be more difficult, and may be impossible, for you to use the Service or portions of the Services.
● Location and Analytics. If we use Third-Party Services to automatically collect your personal information, such Third-Party Services may offer you a choice to stop the automatic collection of your information. Please see our “How we collect your personal information” above with respect to our tracking tools.
● Cookies. Most web browsers are set by default to accept cookies. You can usually set your browser to remove or reject cookies. Please note if you choose to reject, this could affect the availability and functionality of our Services.
● Not Providing Personal Information. You may choose not to provide personal information to us. However, if you do not provide personal information, we may not be able to offer you all or part of our Services.
Where Your Information Is Stored
We store your information in the United States. However we may transfer your information to our service providers who may reside in other countries.
By using the Services or otherwise providing information to us, you understand and consent to having any personal information transferred to and processed in the United States. If you reside in the European Union (the “EU”), we will transfer your personal information pursuant to EU data protection laws. You understand that the United States may not provide the same level of protections as the laws in your country. United States data protection and other relevant laws may not be the same as those in your jurisdiction. In certain circumstances law enforcement or regulatory agencies, courts or security authorities in the United States may be entitled to access your personal information.
We use commercially reasonable security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. However, we cannot guarantee the complete safety of your information. It is your responsibility to keep your information confidential.
How Long We Keep Your Information
We retain, store and use your information for least amount of time necessary for our relationship with you and to provide you access to our Services and in accordance with data retention policies and applicable law.
Our Services Are Not Intended For Children
Our Services is not directed to children under the age of 18. We do not knowingly collect information, including personal information, from children. If we obtain actual knowledge that we have collected such information from children, then we will promptly delete it. If you believe we have mistakenly collected information from children listed above, please contact us at email@example.com
Information for European Economic Area Residents
. If you have a concern about our processing of personal information that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside.
"Do Not Track" Policy as Required by California Online Privacy Protection Act (“CalOPPA”)
Our Service does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Usage and Deletion of Personal Information
You may request what personal information we have collected, used and disclosed about you as well as the identity of the third parties to which we have disclosed your personal information. You may also request deletion of your personal information. Please note that we may not delete all of your information if: (1) we need it to complete a service as requested by you or perform under a contract we have with you; (2) we need such information to repair any errors to our Services or detect data security violations; or (3) we need such information to protect against fraud or illegal activity or to comply with applicable law. Please note that if we delete your personal information, we may not be able to provide you the Services with the same functionality.
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