Last Updated: January 1, 2023
Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. Also, we collect information related to businesses, companies, institutions, or other entities rather than individuals ("Business Information"). We do not consider Business Information such as title, employer's name, work email, work phone number, work address, and other similar business information to be Personal Information.
The Gramm-Leach-Bliley Act ("GLBA") is also known as the Financial Modernization Act of 1999. Please review this notice to understand how we collect, share and protect information under the GLBA.
If you are a California resident, please also review our California Resident Privacy Notice for more information about the types of Personal Information we collect and disclose, as well as how to exercise your rights under California law.
Information We Collect
We may collect a variety of information from or about you or your devices from various sources as described below.
Information You Provide Directly to Us
Registration. when you register to use our Services, we ask for your email address, username, and password.
- Profile Information. You have the ability to update your profile at your discretion and may provide additional information such as your legal name, city, state, and profile pic.
- Investment Account. If you create an investment account through our Services, we will ask for for additional information such as your account type (e.g., individual, joint, IRA), legal investing account name, date of birth, phone number, taxpayer ID number or Social Security Number, account address, employer, job title, industry, income, and employer address. We may also ask for your accreditation status and ask for additional documentation required to verify your accreditation status.
- Verify Your Identity. For security purposes, we may request additional information from you to verify your identity. For example, we may collect your social security number, date of birth, address, and copy of your government-issued identification (e.g., driver's license, passport). We may also use two-factor authentication to protect your login information.
- Communications. If you contact us directly, we may receive additional information about you. For example, we may receive your name, email address, the contents of a message or attachments that you send to us, and other information you choose to provide. If you participate in one of our surveys or polls, we may receive information about you relating to the subject matter of the survey or poll. If you subscribe to a newsletter, then we will collect certain information from you, such as your email address. When we send emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
- Careers. If you decide that you wish to apply for a job with us, you may submit your contact information, resume, and other related information online. We will collect the information you choose to provide on your resume, such as your education and employment experience.
Funding and Distribution Information. If you invest through our Services, we use third party payment processors (see Payment Processors below) that will collect your bank account information to transfer money into your investments and fulfill distributions.
Information We Collect When You Use our Services
- Device Information. We receive information about the device and software you use to access our Services, including IP address (which may provide us with your general location information), web browser type, operating system, application installations, and push notifications.
- Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or content you view, your browsing history, the searches you conduct, people you follow, investments you make, your comments, any content you post, clickstream data, advertising interactions, and the dates and times of your visits.
- Information from Cookies and Similar Technologies. We and our third-party partners (e.g., Google Analytics, HubSpot, SendGrid) collect information using cookies, web beacons, pixel tags, or similar technologies. Our third-party partners may use these technologies to collect information about your online activities over time and across different services.
- Cookies are small text files containing a string of alphanumeric characters. We or our third-party partners, may use both session cookies and persistent cookies. A session cookie disappears after you close your browser or exit the mobile application. A persistent cookie remains after you close your browser or mobile application and may be used on subsequent visits to our Services. As text files, cookies cannot read information on your hard drive, run programs, or deliver viruses to your device.
- Web beacons, also known as clear GIFS, are often used in combination with cookies. Often transparent, these images are part of web pages, and allow us to count users who have visited certain pages and to generate statistics about how our Services are used. They are not used to access Personal Information.
- Pixel tags enable us or our third-party partners to send email messages in a format that can read, and they tell us whether such email has been opened. We may use this information to reduce or eliminate messages sent to you.
Please review your browser or operating system's "help" file to learn the proper way to modify your settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to fully utilize the features of the Service to their total potential.
Information We Receive from Third Parties
- Credit Reporting Agencies. If you are a curator, we may receive information about you from credit reporting agencies to comply with applicable laws and industry standards, such as Know Your Business or Know Your Customer (KYC) and Anti-Money Laundering (AML). For example, we may receive from your pass/fail status of KYC and AML.
- Registration Information. You can log in to the Services using third party credentials such as Apple or Google. These services will authenticate your identity and provide you the option to share certain personal information with us, such as your name and email address to pre-populate our registration form.
- Other Sources. We may obtain your personal information from other third parties, such as marketing partners, data providers, and publicly-available sources such as governmental records.
How We Use the Information We Collect
We use the information we collect:
- To provide, maintain, improve, and enhance our Services;
- To personalize your experience on our Services such as by providing tailored content and recommendations;
- To understand and analyze how you use our Services and develop new products, services, features, and functionality;
- To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
- To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports;
- To send you text messages and push notifications;
- To facilitate transactions and payments (see Payment Processors below);
- To find and prevent fraud, and respond to trust and safety issues that may arise;
- For compliance purposes, including enforcing our Terms of Services or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
- For other purposes for which we provide specific notice at the time the information is collected.
We will not sell, rent or lease any information we collect from you to others.
We only use your Personal Information for the original purposes it was given and to further our legitimate interests, such as to enroll members into our Services, provide information about our organization, to verify identifies, to process payments, and to communicate with visitors. Personal Information is also used to provide you with a more enjoyable, convenient online experience. We may use your Personal Information to send you requested information, to personalize content for you, to compile, analyze, and better understand user data, demographics and behavior, and to detect, investigate, and prevent activities that may violate our policies or be illegal. We may also use your Personal Information to communicate with you about events and services we believe you might find of interest and to administer marketing materials and surveys in which you might participate.
How We Share the Information We Collect
Employees. Our employees and agents may view your Personal Information to perform their jobs and address you needs. We authorize their access to your Personal Information on a need-to-know basis to provide you with information or services, or for one of the other reasons listed in the preceding section, and always in connection with a contractual obligation to protect the privacy of that information.
Vendors or Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
Curators. if you indicate an interest in making an investment through the Services, such as indicating an interest to buy equity in a particular series asset offering, we may notify the party or parties offering the investment and their affiliates of your interest and may notify other users with whom you have chosen to share information.
Social Networks and Other Online Services. Our Services allow you to, upon our direction, share information with social networking services, such as Twitter, Facebook, and Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third-party platforms and your settings on that platform. We encourage you to review their privacy policies.
Marketing. We do not rent, sell, or share information about you with non affiliated companies for their direct marketing purposes, unless we have your permission.
Analytics Partners. We use analytics services including Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google's practices by visiting Google Privacy & Terms. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, your browsing history, the searches you conduct, people you follow, investments you make, your comments, any content you post, clickstream data, advertising interactions, and the dates and times of your visits. You can opt-out of having your site activity available to Google Analytics by installing a browser add-on which can be found here on Google's help center.
Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt-out of personalized ads in mobile apps.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others' rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.
Consent. We may also disclose your information with your permission.
How Long We Retain Your Information
We store your information for as long as is necessary for the purposes identified in this Privacy Notice, including to provide our Services, to comply with legal obligations, to enforce and prevent violations of our Terms of Service, to protect against fraudulent activity, and to defend our legal rights, property and users.
- Sharing Preferences. We provide you with settings to allow you to set your profile and other sharing preferences on the Services. Certain information may always be publicly available to others, and other information is made publicly available to others by default. To change whether certain information is publicly viewable, you can adjust the settings in your account within the mobile application.
- Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails or by contacting us at firstname.lastname@example.org. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative message from us.
- Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
To facilitate financial transactions on our Services we use Dwolla and Plaid. When you engage in a financial transaction, you direct us to share certain information with these payment processors, and you will provide other information such as your bank account information directly to them. We do not record or maintain this financial information. For more information on how transactions are handled, or to understand the data security and privacy practices of these payment processors, please refer to the privacy notices of Dwolla and Plaid.
In addition, we may process electronic fund transfers ("EFTs") as a method to receive electronic deposits from users, to purchase or redeem investments and to issue refunds to users. EFTs are processed through an automated clearing house (ACH) and Fedwire. EFTs allow you to participate in by purchasing securities, offerings by our affiliates. In order to use this payment functionality we share your identity and bank account information collected via Plaid with Templum Markets LLC, a broker-dealer registered with the SEC and member FINRA and SIPC, and with DriveWealth also a broker-dealer registered with the SEC and member FINRA and SIPC.
Update Your Information
You can update your account and profile information or close your account through your profile settings within the mobile application.
If you wish to deactivate your account, you can do so by logging into your account or by emailing us at email@example.com.
If you have any questions, comments, or concerns about our activities, please email us at firstname.lastname@example.org.