Last modified: April 30, 2020
- On our Site
- In email, text, and other electronic messages between you and the Company.
- Through mobile and desktop applications you download from this Site, which provide dedicated non-browser-based interaction between you and our Site.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by Company or any third party, or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site
Types of Information We Collect
“Personal Information” means information that can be used to identify and contact you.
Personal Information – When you visit or use the Site we may gather certain information using automated means (e.g., cookies and web beacons) including, but not limited to, device identifiers, IP address, browser version and configuration, and operating system details, language preferences and length of visits. We also collect information that you voluntarily input into our websites or mobile applications. For example, if you commence using our Services we may collect the information you provide or authorize us to collect, such as your name, e-mail address, certain financial information, your full legal name, citizenship, contact information, date of birth, social security number and other information that may be used to identify you.
From individual companies (“Issuers”), Personal Information may include your company name, email address, phone number, facsimile number, business address, state of incorporation, date of incorporation, and officer and director information (including, but not limited to, each such officer’s and director’s name, personal address, date of birth, phone number, facsimile number, occupation and biography, and other information relevant to confirming they are not a “bad actor” within the rules and regulations promulgated under the Securities Act of 1933, as amended (the “Securities Act”).
From investors (“Investors”), Personal Information may include your name, email address, phone number, facsimile number, personal address, social security number, bank account information, and other information necessary to verify your identity and status as an accredited investor within the meaning of Rule 501 of Regulation D promulgated under the Securities Act or as an investor qualified to purchase securities offered under Regulation A or Regulation CF (including, but not limited to, accredited investor questionnaire information, information in W-2s, information in brokerage statements, credit report information, information in tax returns, information in letters from your certified public account, legal counsel, or registered broker-dealer).
We may also conduct business and collect Personal Information from individuals and institutions located within the European Economic Area (“EEA”). We are required to protect Personal Information processed in the EEA in accordance with the General Data Protection Regulation. To understand more about how we protect the data we collect from individuals and institutions located within the EEA, please see the “Privacy Statement for Data Subjects Whose Personal Information May Be Collected in or from the EEA” section below.
Use of Information
Additionally, we may make your Personal Information non-personally identifiable by either combining it with information about other users (aggregating your Personal Information with information about other users), or by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing your information. You grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your Personal Information in connection with the creation and development of analytical and statistical analysis tools relating to the use of the customer data we collect (the “Analytical Data”). We are expressly authorized to make any commercial use of the Analytical Data, including without limitation, sharing the Analytical Data with third parties.
If you are located within the EEA, your Personal Information will not be retained without your consent.
Cookies and other Technical Information
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on our Site.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to:
- Estimate the size of our user base and usage patterns.
- Store information about your preferences, allowing us to customize our Site according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Site.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our Site and our e-mails 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 opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Our servers may automatically record information that your browser sends whenever you visit the Site. This information includes your Internet Protocol address, your browser type and version, the search engine you used to find the Site, if any, and your geo-locational information. We use this information to monitor and analyze how users use the Site, provide customer service and to maintain and improve the Site.
We may employ third party tracking utility software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. In short, clear gifs enable two websites to share information with one another. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.
“Do Not Track”
In compliance with California legislation, AB370, effective January 1, 2014, the Company’s practices in responding to “do not track” signals and collecting user information over time and across a network of websites when you visit the Site are described below. We honor the request of “do not track” signals sent by your browser when you visit the Site. Additionally, the Company does not collect user information about your online activities over time and across different websites or authorize third parties to do so.
Children Under the Age of 16
Our Site is not intended for children under 16 years of age. No one under age 16 may provide any Personal Information to or on our Site. We do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on this Site or through any of its features, register on our Site, make any purchases through our Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at firstname.lastname@example.org.
California residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Information. Please see section below on Your California Privacy Rights for more information.
Sharing of Information
- Investors. We may share your information with certain third parties to conduct background checks to verify your status as an Accredited Investor under the Securities Act. We may also share your information with banking partners in order to create a bank account for investing in Offerings. The Company may also share your Personal Information with other third parties necessary to effect the investment transaction, including a third party escrow provider and affiliated transfer agent.
- Protection of rights. We will share Personal Information if we have a good faith belief that (i) access, use, preservation or disclosure of such information is reasonably necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (ii) such action is necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with the Site, or (iii) such action is appropriate to protect the rights, property or safety of the Company, its employees, clients, or users of the Site and Services.
- Asset Transfers/Mergers/Strategic Transactions. If we become involved in a merger, acquisition or other transaction involving the direct or indirect sale of some or all of the Company’s assets, user information, including Personal Information collected from you through your use of the Site and Services, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you through a prominent notice on the Site.
- Third Party Vendors. We may share Personal Information with third party vendors so that they may provide support to our business operations, including banking services, escrow services, data processing, data storage, surveys, research, internal marketing, delivery of promotional, marketing, and transactional materials, and the Site’s maintenance and security
- To our subsidiaries, affiliates, contractors, service providers, and other third parties we 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 necessary to satisfy any applicable law, regulation, legal process, such as a court order or subpoena, or a request by law enforcement or governmental authorities, (b) as appropriate to enforce its policies and procedures, (c) if necessary to detect, prevent, or otherwise address fraud, security or technical issues associated with this Agreement or the Services, or (d) if appropriate to protect the rights, property or safety of the Company, its employees, or other users of the Services.
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use an “email a friend” feature of our Site, if any, we will transmit the contents of that email and your email address to the recipients.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
Control of Your Information
You may update or delete your Personal Information at any time. Please note that when you ask to delete Personal Information, we may still retain your account information for a reasonable period of time afterward for the purpose of internal account management, meet regulatory recordkeeping requirements and fraud prevention activities.
In some cases, we may not be able to delete your Personal Information and will retain and use your information as necessary to comply with our legal obligations, regulatory recordkeeping requirements, resolve disputes, operate our business, manage your account, and enforce our agreements.
Privacy Statement for Data Subjects Whose Personal Information May Be Collected in or from the EEA
We may collect Personal Information from customers located in the EEA. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use this Site and our Services. If you are located in the EEA or Switzerland, we take measures to comply with applicable legal requirements and ensure adequate protection for the transfer of personal data to recipients in countries outside of the EEA or Switzerland, for instance through data transfer agreements based on the EU Commission’s model clauses, or a Privacy Shield certification.
Customers located in the EEA may withdraw consent at any time where consent is the lawful basis for processing their Personal Information. Should a customer withdraw consent for processing or otherwise object to processing that impedes our ability to comply with applicable laws and regulations, such customer may be unable to avail him or herself of the Site or Services we provide.
International Data Transfers (Non-EEA)
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the Personal Information you provide to us. We may at times send you e-mail communications with information, marketing or promotional materials. If you prefer not to receive such e-mails from us, you may unsubscribe completely by contacting us at email@example.com. Please note that opt-out requests may take up to five (5) business days to process. Please also note that at times we may need to send you e-mail 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.
You will be able to modify the information concerning your account by visiting your profile page and editing any information you wish to change. You will be able to view and change your e-mail address, password, financial information, contact information, or other login information by visiting your account’s settings page subject to our Site policy. If you wish to suspend your account or need help modifying account information, please contact us at firstname.lastname@example.org.
Through your account settings you may be able to set certain preferences and permissions regarding the visibility of your information, Personal Information, to others. You may stop or restrict the placement of cookies on your computer by adjusting your web browser preferences or a “Do Not Track” setting in your web browser. If you do so, you may still use our Site, but this may interfere with some of its functionality. You may also clear cookies from your computer via your web browser settings. If you would like us to remove your Personal Information from our database, please send a request through the contact at email@example.com.
California residents may have additional Personal Information rights and choices. Please see section below on Your California Privacy Rights for more information.
Your California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to
firstname.lastname@example.org or write us at: 58 Main Street, Fl. 3, Hackensack, New Jersey 07601.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of our Site like message boards. The information you share in public areas may be viewed by any user of our Site.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Site. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Site.
58 Main Street, Fl. 3, Hackensack, New Jersey 0760