Payment processors

Job applicants

Other sites, mobile applications and services

Security practices

Children

Changes to this Privacy Policy

How to contact us

Additional information for users located in California

Personal information we collect

Information you provide to us:

Contact information, such as your first and last name, email and mailing addresses, and phone number.
Account information, such as your date of birth, Social Security number (or other government-issued verification number(s)), and citizenship.
Investment information, such as accreditation documents.
Financial information needed to transfer money to us and transact on our services, including your bank account details that you provide to us when you make a payment through our site. We will allow you to connect your financial accounts to our services through our service providers. Please see the “Payment processors” section below for additional information regarding how our third-party payment processors handle your personal information.
Payment and transaction information needed to complete your transactions, including name, payment card information, billing information. This information is processed by our payment service provider, Stripe. We do not have access to payment card numbers. Please see the “Payment processors” section below for additional information regarding how our third-party payment processors handle your personal information.
Feedback or correspondence, such as information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us online.
Usage information, such as information about how you use our services and interact with us, including information associated with any content you upload to our services or otherwise submit to us, and information you provide when you use any interactive features of our services.
Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
Other information, that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties:

Social media information. We may maintain pages on social media platforms, such as Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
Third-party login information. When you link, connect, or login to our services with a third-party service (e.g., Google, Facebook, or LinkedIn), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings on that service.
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.

Automatic data collection

We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our services, our communications and other online services, such as:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
Online activity data, such as the pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

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How we use your personal information

To operate our services:

Provide, operate, maintain, secure and improve our services
Fulfill payments and transactions
Provide information about our services
Communicate with you about our services, including by sending you announcements, updates, security alerts, and support and administrative messages
Understand your needs and interests, and personalize your experience with our services and our communications
Respond to your requests, questions and feedback

For marketing and advertising.

We and our advertising partners may collect and use your personal information for marketing and advertising purposes, including:

Email. We or our advertising partners may from time-to-time send you direct marketing emails as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email. You may opt out of our marketing emails as described in the “Opt out of marketing communications” section below.
Text messages. We may notify you via text message about upcoming investment opportunities and other alerts you request. If you would like more information about our do-not-call policy, or how to opt out, please review the “Opt out of marketing communications” section below. You may be liable for standard SMS and per-minute charges by your mobile carrier.
Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the “Automatic data collection” section above) over time across our Services, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Online tracking opt-out” section below.

To comply with law

As we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety

To: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

For research and development

We may create and use de-identified information for our business purposes, including to analyze the effectiveness of our services, to improve and add features to our services, and to analyze the general behavior and characteristics of users of our services. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes.

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How we share your personal information

Affiliates

We may share your personal information among our affiliates. We may also share the personal information of our business contacts among our affiliates for each affiliate’s own purposes.

Service providers

We may share your personal information among our affiliates or with third-party companies that provide services on our behalf or help us operate our services (such as customer support, hosting, analytics, email delivery, marketing, identity verification, billing, accreditation document processing and database management services).

Advertising partners

We may share your personal information with third-party advertising companies, including for the interest-based advertising purposes described above.

Professional advisors

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety

We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers

We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

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Your choices

Access or update your information

If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications

You may opt out of marketing-related communications – both email and text – by following the opt-out or unsubscribe instructions within the marketing communication we send you. You may also contact us via the Contact page to unsubscribe or learn more about our do-not-call policy. Even if you opt out of marketing-related communications, you may continue to receive service-related and other non-marketing emails.

Online tracking opt-out

There are a number of ways to opt out of having your online activity and device data collected through our services, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block cookies/trackers.
Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising: Google; Facebook; LinkedIn; Microsoft.
Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:Digital Advertising Alliance; Network Advertising Initiative.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com

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Payment processors

To facilitate financial transactions on our services, we use Dwolla, Plaid and Stripe. 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 credit card or 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, Plaid and Stripe.

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Job applicants

When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes name, contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or provided during interviews (which may be recorded). This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information.

We use applicants’ information to facilitate our recruitment activities and process employment applications, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants’ information to administer the employment relationship. We may also use and disclose applicants’ information to improve our website and for the compliance and protection purposes described above.

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Other sites, mobile applications and services

Our services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

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Security practices

We use organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

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Children

Our services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through our services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

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Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy.

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How to contact us

Please direct any questions or comments about this Policy or privacy practices via the Contact page of this site.

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Additional information for users located in California

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide this CCPA notice (“CCPA Notice”) to California residents to explain how we collect, use, and share their personal information, and the rights and choices we offer California residents regarding our handling of their personal information.

CCPA scope and exclusions

This CCPA Notice and the CCPA privacy rights apply only to California residents whose interactions with us are limited to:

Visiting our websites;
Signing up for email alerts; or
Applying for our job openings on our websites (however, note that the CCPA limits some of the privacy rights for job applicants).

This CCPA Notice does not apply to the personal information we collect, use, or disclose about:

Consumers who initiate or complete the process of applying for financial products or services. This is because that information is subject to the federal Gramm-Leach-Bliley Act and implementing regulations, or the California Financial Information Privacy Act (for additional information relating to your choices about this information specifically, see our GLBA Privacy Notice ; or
Representatives of businesses that seek to obtain our products or services, or to provide products or services to us.
Your California privacy rights

The CCPA grants individuals the following rights:

Information. You can request information about how we have collected and used your Personal Information during the past 12 months. We have made this information available to California residents without having to request it by including it in this Privacy Policy.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.

You are entitled to exercise the rights described above free from discrimination.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

How users in California can exercise their rights

You may exercise your California privacy rights described above as follows:

Right to information, access and deletion. You can request to exercise your information, access and deletion rights via the Contact page in this site.
Right to opt out of sale of personal information. To the extent the CCPA applies to our services, we do not sell personal information. We use third-party tracking technologies on our websites, like many businesses, and we offer instructions on how to limit online tracking in the “Online tracking opt-out section of this page, under Your Choice”
Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority

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