Privacy Policy

Welcome! We are committed to safeguarding the privacy of our website visitors; in this policy, we explain how we will treat your personal information on the website SITE NAME.

By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

This privacy policy (“Privacy Policy”) governs the website www.SITE NAME (including both mobile and online versions) (the “Site”), online and mobile services (e.g., apps), and software made available by SITE NAME, Inc. and/or its subsidiaries (“SITE NAME”, “we”, “our” or “us”), including your use of interactive features, platforms, widgets, plug-ins, applications, content, downloads and/or other online services that we own and control and that post a link to this Privacy Policy (collectively with the Site, the “Service”). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Service.

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Service’s Terms of Use, which governs your use of the Service. By using our Service, you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use this Service.

• We may use your Personal Information, Business Information or Usage Information that is subject to this Privacy Policy:
• to determine a potential investor’s suitability to be an investor on the Service;
• to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming events;
• to process and track your investments and other transactions you enter into using the Service;
• to verify your identity, including your accounts on the Service;
• to manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
• to manage and protect our information technology infrastructure;
• to provide the Service, including the marketplace opportunities available on the Service;
• to improve the Service, marketing endeavors or our Service offerings;
• to customize your experience on the Service or to serve you specific content or ads that are relevant or personalized to you;
• to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
• to contact you with regard to your use of the Service and, in our discretion, changes to the Service and/or Service’s policies;
• to identify your product and Service preferences so that you can be informed of new or additional products, services and promotions;
• to enable you to participate in a variety of the Service’s features;
• to remember information so that you will not have to re-enter it during your visit or the next time you visit the Service;
• to diagnose or fix technology problems with the Service;
• to improve the overall experience at the Service;
• to comply with our legal and regulatory obligations;
for internal business purposes; and for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this policy.

Personal information submitted to us through our website will be used for the purposes specified in this policy or on the relevant pages of the website.

We may use your personal information to:

• administer our website and business;
• personalise our website for you;
• enable your use of the services available on our website;
• send you information through our website;
• provide to you investment services through our website;
• collect payments from you and send you payments (profits);
• send you non-marketing commercial communications;
• send you email notifications that you have specifically requested;
• send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
• send you marketing communications relating to our business;
• (k) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
• deal with enquiries and complaints made by or about you relating to our website;
• keep our website secure and prevent fraud;
• verify compliance with the terms and conditions governing the use of our website [(including monitoring private messages sent through our website private messaging service) ; and]
• other uses.

If you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant to us.

We will not, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

We may disclose your personal information insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information to any member of our group of companies insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal information:

• (a) to the extent that we are required to do so by law;
• in connection with any ongoing or prospective legal proceedings;
• (c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
• to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this policy, we will not provide your personal information to third parties.

Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.

Personal information that you publish on our website can not be available, via the internet, around the world. We prevent the use or misuse of such information by others.

We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password- and firewall-protected) servers.

All electronic financial transactions entered into through our website will be protected by encryption technology.

You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).

We may update this policy from time to time by publishing a new version on our website.

You should check this page occasionally to ensure you are happy with any changes to this policy.

We may notify you of changes to this policy [by email or through the private messaging system on our website].

You may instruct us to provide you with any personal information we hold about you.

(a) User Content and Public Information.

The Service may permit you to submit ideas, photographs, investment information, investing experience, company information video, audio recordings, computer graphics, pictures, data, information about your location, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on publicly available investment profiles. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties.

Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that SITE NAME does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure.

We are not responsible for the privacy or security of any information that you make publicly available on the Service or what others do with information you share with them on the Service. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Service.

(b) Name and Likeness.

We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Service, please review our Service’s Terms of Use.

We and third parties such as network advertisers and ad exchanges may serve advertisements on the Service or across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content.

Network advertisers are third parties that display advertisements, which may be based on your activities across the Internet and mobile media (“Behavioral Ads”). Behavioral Ads enable us to target advertisements to you for products and services in which we believe you might be interested. If you object to receiving Behavioral Ads from us on third party sites, you can learn more about your ability to limit Behavioral Ads below.

Our third party ad network and exchange providers, the advertisers and/or traffic measurement services may themselves set and access their own technologies on your Device and track certain behavioral Usage Information via a Device Identifier.

These third party technologies may be set to, among other things:

(a) help deliver advertisements to you that you might be interested in;

(b) prevent you from seeing the same advertisements;

(c) understand the usefulness of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.

Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

Some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. Further, while sites use a variety of companies to serve advertisements, you may wish to visit http://www.networkadvertising.org/optout_nonppii.asp, which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members.

Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver Behavioral Ads to you, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. You may also opt-out of receiving Behavioral Ads on participating sites and services by visiting the Digital Advertising Alliance (“DAA”) website at http://www.aboutads.info/choices. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options or programs.

Our Service is operated in the United States and intended for users located in the United States.

If you are located outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States.

By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

Our website uses cookies.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use only session cookies on our website.

Most browsers allow you to refuse to accept cookies; for example:

• (a) in Internet Explorer you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
• in Firefox you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
• in Chrome, you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.

Blocking all cookies will have a negative impact upon the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

11.9. You can delete cookies already stored on your computer; for example:

• in Internet Explorer, you must manually delete cookie files (you can find instructions for doing so at http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11);
• in Firefox (version 39), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history" from the drop-down menu, clicking "Show Cookies", and then clicking "Remove All Cookies"; and
• in Chrome, you can delete all cookies by accessing the "Customize and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Cookies and other site and plug-in data" before clicking "Clear browsing data".

11.10. Deleting cookies will have a negative impact on the usability of many websites.

12. Does Third-Party Content, Links to Third-Party Sites, and/or Third-Party Apps Appear on the Service?

When you are on the Service you may be directed to other sites and apps that are operated and controlled by third parties that we do not control such as merchants who directly sell products and services to you. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others.

These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Service onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies.

We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.

We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.