Last modified: April 16th, 2019
Information We Collect About You and How We Collect It
Information we collect about you when you visit our website or use our Service can be: (i) Personally Identifiable Information; and/or (ii) Anonymous Information. “Personally Identifiable Information” is any information that could reasonably be used to identify you, and “Anonymous Information” is information that cannot be used to identify you personally such as statistical information concerning, for example, the time spent on a particular page of our website.
We may collect Personally Identifiable Information about you in the various ways described below. Please keep in mind that if you do not provide certain Personally Identifiable Information to us when requested, you may not be able to register or use our Services if that information is necessary for that purpose or if we are legally required to collect that information.
Information You Provide to Us as a Registered User or Investor
When you register to become a user of our Service, you will need to provide Personally Identifiable Information, which could include your: (i) first and last names; (ii) e-mail address; (iii) home or work addresses; (iv) social security/tax ID number (for IRS tax reporting); (v) financial information; (vi) birth date; (vii) username; (viii) telephone number (home, work, or mobile); (ix) employer name and/or job title; or (x) password.
You may also provide us with Personally Identifiable Information through other means such when you send us an e-mail, post any content on our website, submit information or answers through forms on our website, send messages to other users on our website, or participate in investment opportunities available on our Service.
If you become an investor on our Service, you may provide us with the above enumerated Personally Identifiable Information in addition to other information such as: (i) your business name, address, email and phone number, and names of owners and management, if applicable; (ii) 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; (iii) citizenship status; (iv) payment information which may be needed to make payments via ACH, wire, electronic checks, or any other payment method accepted by us at such time; (v) a completed IRS Form W-9 (which would include social security/taxpayer ID numbers); (vi) your answers to further questions asked during the creation of your user profile.
You may also be asked for the following Personally Identifiable Information in order to help us validate your identity: (i) your driver’s license information, government issued identification number; or (ii) other Personally Identifiable Information we may need for verification.
Information We Collect Through Automatic Data Collection Technologies
In addition to information you provide to us voluntarily as described above, as you navigate through our website and Service, we may use automatic data collection technologies such as, for example, cookies, to collect certain information about your interaction with our Service, which in large part will be Anonymous Information such as: (i) details of your visits to our website such as traffic data, click stream data and other communication data and the resources that you access and use on the Service; and (ii) information about your computing device (e.g., desktop or mobile), operating system, and browser type.
Please note however that while the vast majority of information we automatically collect will be Anonymous Information such as statistical data, we may maintain it or associate it with Personally Identifiable Information we collect in other ways or receive from third parties. This helps us to improve our Service and website and to deliver a more personalized service to our users by allowing us to, for example: (a) speed up searches; (b) estimate our audience size and usage patterns; (c) store information about your preferences, allowing us to customize our website according to a user’s individual interests; or (d) recognize a user when they return to our website.
To learn more about the automatic data collection technologies we may use, please review the section below entitled “Our Cookies Policy.”
Our Cookies Policy
Browser Cookies: A browser cookie is a small text file placed on the hard drive of your computer or device by our website. You can choose to not accept browser cookies by adjusting your web browser settings. However, if you do so, you may be unable to access certain parts of our website or lose some of the functionality of our Service. Unless you have set your browser not to accept browser cookies, our system will issue cookies when you direct your browser to our website.
Flash Cookies: Some features of our website or Service may use flash cookies (a/k/a local stored objects) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons: Some pages of our website may contain small electronic files known as web beacons (a/k/a clear gifs, pixel tags, or single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics.
You can also choose to opt-out of Google Analytics if you wish. To learn more about this, you may visit the following link: https://tools.google.com/dlpage/gaoptout
We use the automatic data tracking technologies discussed above for the following purposes: (a) to present our website and its contents to you; (b) to provide you with information, products, or services that you request from us; (c) to fulfill any other purpose for which you provide it; (d) to provide you with notices about your registration to our Service; (e) to carry out our obligations and enforce any rights arising from any contracts entered into on our website, including for billing and collection; (f) to notify you about changes to our website or any products or services we offer or provide though it; (g) to allow you to participate in interactive features on our website; (h) in any other way we may describe when you provide the information; (i) for any other purpose with your consent; (j) we may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you; and (k) we may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.
Opting-Out and Managing Cookies: When you visit our website or use our Service through a web browser, you can change the settings in your browser to alter the cookie preferences, including not accepting cookies. We have provided links below to further information on how to manage cookies depending on the browser you use.
Microsoft Internet Explorer:
Mobile Devices: If you access our website or Service through a mobile device or our mobile application, you can learn more about changing your cookie preferences by visiting the following link corresponding to your mobile operating system:
How We Use Information We Collect
We use information we collect about you or that you provide to us, including Personally Identifiable Information:
To present our website and its contents to you;
To provide disclosures to you that we are required to provide under applicable law in connection with any investment opportunities you may participate in through our Service;
Operate and provide our Service to you, including to verify your identity and process transactions you participate in, including allowing us to process payments;
To provide you with information on investment opportunities, products, or services that you request from us;
To contact you about our own or third-parties’ goods and services that may be of interest to you;
To respond to your inquiries, and send you transaction-related emails or service notifications;
To provide you with notices about your account or registration, including expiration and renewal notices;
To analyze and improve our website and Service, including analyzing your preferences and interests in order to provide you with tailored content;
To protect our website and Service, including protecting your and other users’ accounts;
Enforce our Terms, our legal rights, and to comply with applicable law, a subpoena, or other legal process, or to protect against liability and when we believe in good faith that disclosure of your information is necessary to protect our rights, protect your or other users’ safety, investigate fraudulent activity, or respond to legal requests from governmental authorities;
To allow you to participate in any interactive features on our Service; and
To fulfill any other purpose for which you provide your information to us including any way we describe when you provide the information to us or for any other purpose with your consent.
How We May Disclose Your Information
We may share aggregated anonymous information about our users, and other information that does not identify any particular individual, without restriction.
To our subsidiaries and affiliates;
To contractors, service providers, and other third parties we may use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
If you are an investor, to third parties or service providers in order to verify your identity and status as an investor under applicable securities laws, to facilitate your payment and any escrow of funds, to record investments you participate in with third-party transfer agents, and to provide you with necessary tax reporting information and documentation;
To a buyer or other successor-in-interest to our Company in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personally Identifiable Information held by us about the users of our website and Service is among the assets transferred;
To comply with any court order, law, or legal process, including to respond to any government or regulatory requests;
To enforce or apply our Terms and other agreements, including for billing and collection purposes;
If in our reasonable judgment we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our Company, our employees or customers, or others, including exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction; and
To fulfill the purpose for which you provide it, or for any other purpose disclosed by us when you provide the information.
Your Choices About How We Use and Disclose Your Information
We aim to provide you with choices regarding your Personally Identifiable Information that you provide to us. Toward that end, we have implemented certain features to provide you with control over your information, namely:
Account Information: You will be permitted to access your account (with an established user name and password) in order to change certain personal information about yourself. However, as an investor, you will be required to keep certain information current such as Form W-9 information. We ask that you keep any investor information current as we may have to use such information to provide you with investment opportunities and financial distributions.
Opting-Out of Certain Communications: We may on occasion send you marketing or promotional emails about our products and services or those of a third-party. If you choose not to receive such emails from us, you can unsubscribe by contacting us at email@example.com or by following the “unsubscribe” instructions included in the emails. Please note however that you will not be permitted to opt–out of any communications we are required by law to send to you, other related notices concerning your use of our website or Service such as emails notifying you of changes to the same, or transaction-based emails such as emails confirming your participation in particular investment opportunities.
Deleting or Changing Your Information: Upon you request by contacting us at firstname.lastname@example.org, we will take reasonable steps to delete or change any Personally Identifiable Information you request to be removed or changed from our records or database. Please note however that it might be impossible for us to remove or change this information completely because of IRS or regulatory reporting requirements, investments on our Service and the rights thereof, and data backups and records of deletions. We may also not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you request deletion or change of your information, you may be unable to use certain features of our Service or participate in investment opportunities. Certain Personally Identifiable Information may remain in our databases following the deletion of your account. You may not remove de-identified, anonymous, or aggregate data from our databases.
We will retain your information for as long as your account is active or as needed to provide you with our Service. If you no longer want to use our Service, you may close your account. However, after closing your account, we may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We use measures intended to secure your Personally Identifiable Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Toward that end, all information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.
Please note that the safety and security of your information also depends on you. Because our website and Service requires registered users to provide unique identifies such as their user ID and password, you are responsible for keeping such user ID and password information confidential. You should not therefore share user ID or password information with anyone. To the extent our website or Service permits you to post information in public areas (e.g., message boards), we urge you to be careful about giving out such information in such public areas. The information you share in public areas may be viewed by other users of our website or Service. You should also avoid sharing computers or devices that you use to access our Service and be sure to log off the Service when you are not using it.
Unfortunately, the transmission of information over the Internet is not completely secure at all times. Although we do our best to protect your Personally Identifiable Information, we cannot guarantee the security of such personal information transmitted to our website. Any transmission of such information is therefore at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our website.
Transfer of Your Information
Because we are based in the United States of America, your Personally Identifiable Information will be collected and processed in the United States, which has its own laws regarding data protection and government access to such information. Please note that the laws and regulations in the United States regarding protection of your Personally Identifiable Information may not be the same as those in the country where you live. Consequently, if you do not wish for your Personally Identifiable Information to be collected and processed in the United States, your only choice is to not visit our website or use our Service.
Incorporation of Our Terms