Last Modified on April 18th, 2016
Our Privacy Commitment
This policy answers the following questions:
- What information do we collect about you and how do we use it?
- Will we share your personal information with third parties?
- What choices do you have about the collection and use of your personal information?
- What security measures do we take to safeguard your personal information?
What information do we collect about you and how do we use it?
Types of Information We Collect
Personal information means information that can be used to identify and contact you. The Site may be browsed anonymously. If you do not browse anonymously, the Site may collect personal information from you including your name, email address, and password when you sign up for an account. Users may also choose to link their accounts with certain third party social media services and upload photographs, all of which will be associated with their account and visible to other users.
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 501of Regulation D promulgated under the Securities Act or as an investor qualified to purchase securities offered under 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).
How We Use Your Personal 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 on the Site (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.
Cookies and other Technical Information
“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we employ cookies in certain areas of the Site to allow us to provide information to make your online experience more convenient. A user may configure his or her web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being set.
A tracking “pixel” is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel. The Company may use third party ad servers to support tracking pixels and cookies.
Our servers automatically record information that your browser sends whenever you visit the Site or Service. This information includes your Internet Protocol address, your browser type and version, the search engine you used to find the Site, if any, which portions of the Service you use and when and how long you use them, your geo-locational information. We use this information to monitor and analyze how users use the Site and Service, to provide customer service and to maintain and improve the Site and Service.
We 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.
You must be at least 18 years of age to use the Site. We do not knowingly collect personal information from children under 13. Please do not send us any personal information if you are under 13 years of age and do not sign up for a newsletter. We take children’s privacy seriously, and encourage parents to play an active role in their children’s online experience at all times. In the event that we learn that we have collected personal information from a minor under 13, we will delete that information and comply with the requirements of the Children’s Online Privacy Protection Act and other applicable law. If you have any concerns about your child’s personal information, please contact us at email@example.com.
Will we share your personal information with third parties?
Sharing of Information
- Investors. If you attempt to register your account as an Investor, 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 will also share your information with banking partners in order to create a bank account for investing in Offerings. FlashFunders will 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.
- Offering. If you attempt to create an Offering on the Site, we will share your personal information with third parties in order to verify certain financial and other corporate data and to conduct background checks. We will also share certain personal information and financial data with other users of the Site, including potential investors. FlashFunders will 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 Service.
- 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 Service, 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. By sharing your personal information with the Company, you are giving us consent to transfer your personal information to a third party in any transfer of the Company’s assets.
Additional Information You Should Know About Third Parties
Our Site uses Mixpanel to help us learn about who visits our site and what pages are being viewed. Learn more at: https://mixpanel.com/privacy/.
What choices do you have about the collection and use of your personal information?
Control of Your Information
You may update or delete your personal information or modify your account preferences for the Site and Service by accessing the account interface of the Site. Please note that when you delete your account, we may retain your account information for a reasonable period of time afterward for the purpose of internal account management and fraud prevention activities.
Opting Out of Receiving Communications from Us
If you no longer want to receive our newsletter, emails or other announcements, you may unsubscribe by selecting “unsubscribe” in your account, writing to us at [firstname.lastname@example.org] or replying to the unsubscribe link at the bottom of our emails. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating to your account transactions.
How to Correct or Delete Your Data
Any individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the below email or physical address. If, for any reason, you are concerned with the way we are using your personal information, or would like to request that we delete such personal information, please contact us at email@example.com, or by postal mail at FlashFunders, ATTN: Privacy Data Request, 15260 Ventura Blvd., 20th Floor, Sherman Oaks, CA 91403. Please include your full name and email address associated with your account and a detailed description of your data request.
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, resolve disputes, operate our business, manage your account, and enforce our agreements.
What security measures do we take to safeguard your personal information?
The personal information that you provide to us is stored on severs that are located in secured facilities and protected by protocols and procedures designed to ensure the security of such information. In addition, we restrict access to personal information to employees, independent contractors and agents who need to know this information in order to develop, operate and maintain the Site and Service. All personnel who have access to this information are trained in the maintenance and security of such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the Site or Service and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.
Notification of Changes
Questions? Contact Us