Effective Date: May 25, 2018
Personal Information We Collect
When you register with us and use the Service, we collect the personal information you submit to us. If a third party registers you with the Service or creates an account for you in the Service (for example, when an Administrator creates an account for an investor), the third party may also provide us with your personal information. This information may include your name, address, email address, social security number, profile picture, bank account information, and other personal information. To the extent you use any portion of the Service for which fees are payable, we may also collect your credit card information or other payment information.
You can alter or update the personal information you submit to us by logging into your account and changing the information. If you update information, we may keep a copy of the prior version for our records. If a third party submits your personal information to us (for example, when an Administrator creates an account for an investor), you may need to contact such third party in order to alter, update or remove such personal information. Please note that if you use the Service to submit personal information to another user (such as an Administrator), you may need to contact that user in order to alter or update the information as maintained by them.
Information We Collect on Behalf of Users
Our Use and Sharing of Your Personal Information
We may use the information we collect to provide and improve the Service, to customize and improve your online experience, and collect any applicable fees related to the Service. We may also send you news, updates and other information you may find useful, unless you specify in your account that you do not want to receive these notices.
Except as described below, we do not share with third parties information by which you can be personally identified unless you give your consent.
- In the event that all or part of our business may be acquired by a third party, we may disclose personally identifiable information in connection with that transaction.
- We may disclose personally identifiable information to third parties who provide limited services on our behalf (for example, the processing of payments, or delivery of emails or other information to you).
- Any personally identifiable information which you include in your publicly-available user profile or submit to publicly-accessible portions of the Service will be visible to the public.
- If a third party registers you with the Service or creates an account for you in the Service (for example, when an Administrator creates an account for an investor), the third party may view your usage and profile data (including how and when your account is used) and access Your Content, including any personally identifiable information included in the foregoing.
- If you use the Service to share any personally identifiable information with a third party (such as another user of the Service), then we may share such information with such third party through the Service as directed. (For example, if you are an investor in a fund that uses the Service, your information may be sent to the related Manager or Administrator in connection with such investment in order for us to provide the Service.)
European Union User Rights
To the extent applicable, the General Data Protection Regulation of the European Union (the “GDPR”), gives you certain rights regarding your personal data, such as the following.
- The right to completely remove your data from our records by submitting a formal request to your fund administrator or fund manager. It is the responsibility for the contacted party to then submit the request to us through an established means of communication.
- The right to access all data pertaining to you by logging into the site or by submitting a formal request to your fund administrator or fund manager. It is the responsibility for the contacted party to then submit the request to us through an established means of communication.
- The right to rectify data by submitting any proposed changes to your fund administrator or fund manager. It is the responsibility for the contacted party to then submit the request to us through an established means of communication.
To the extent required by the GDPR, we have certain additional responsibilities regarding management of your personal data, such as the following.
- That we notify any relevant parties such as fund administrators or fund managers of the extent and dangers of any data breach, when identified.
- That we notify all relevant users of the extent and dangers of any data breach, when identified.
While there is no such thing as “perfect security” on the Internet, we use industry standard security measures to protect against the loss, misuse and alteration of the information under our control.
No one under 13 years of age is authorized to use the Service, and we do not intentionally collect information from anyone under the age of 13.
California Privacy Rights for Minors
To the extent required by applicable law, if you are a registered user of the Service and are under 18 years of age, you may request and obtain removal of content or information you have posted on the Service. In some cases, the Service will enable you to remove such content or information yourself. Otherwise, you may request such removal by emailing us at email@example.com a clear statement describing the content or information you would like removed and its location on the Service. The requested removal does not ensure complete or comprehensive removal of such content or information. In some cases, removal is subject to and limited by the provisions of applicable law (for example, content or information might not be removed if it was reposted by a third party, or if it has been anonymized so that you cannot be individually identified, or if it is rendered invisible to other users and the public.)
California “Do Not Track” Disclosure
We do not collect personally identifiable information about your online activities over time and across third-party websites or online services, and therefore do not respond to “do not track” signals or other mechanisms that allow consumers to exercise choice regarding this type of activity.
Third parties that serve or display advertisements on the Service may collect personally identifiable information about your online activities over time and across different websites when you use the Service.
The Service is provided and operated solely from the United States of America. If you submit any personal information to the Service from outside the United States, you hereby consent to the transfer of such information to (and the processing of such information in) the United States, and the exclusive application of the laws of the State of California, United States, with regard to the collection and use of such information.