VERIFYINVESTOR.COM PRIVACY POLICY
Effective Date: March 22, 2023
Thank you for your interest in VerifyInvestor.com. Verify Investor, Inc. (“VerifyInvestor.com,” “we,” “our,” or “us”) is committed to protecting the privacy of our users, and we strive to provide a safe and secure user experience.
This Privacy Policy describes how we collect and use the information we collect through the website at www.verifyinvestor.com, other websites and applications owned and operated by VerifyInvestor.com, and offline when you contact us electronically, by mail or through our customer service center (together, our “Service”). This includes information collected when you create an account with us on our Service (“Account”).
This Privacy Policy does not apply to websites, mobile applications or services operated by third parties, including affiliates of VerifyInvestor.com. Please refer to the privacy policies for those other websites and mobile applications for the data collection, use, and sharing practices applicable to those websites and mobile applications.
This Privacy Policy includes the following Sections. You can jump to particular topics by clicking the headings below:
What Information We Collect.
Why We Collect Information.
How We Collect Information.
How We Protect the Information We Collect.
How We Share the Information We Collect.
How Long We Retain Your Information.
International Data Transfers.
What Choices and Rights You Have Regarding Your Information.
Additional Information.
How To Contact Us Regarding This Privacy Policy.
WHAT INFORMATION WE COLLECT
The list below includes examples of the types of personal information we may collect from you in connection with our Service:
| Context | Types of Data | Primary Purpose for Collection and Use of Data |
|---|---|---|
| Account Information | We collect your name and contact information when you create an account. such as email address, mailing and physical address, phone or mobile number, zip code, date of birth, information about your spouse, passport or driver’s license numbers, national/tax identification numbers, number and country of issuance of other government-issued documents, and other identification verification when you create an account. We also collect your username and password, and information relating to the actions that you perform while logged into your account. | We have this information to provide account related functionalities to our users, including creating, maintaining, and securing your account, verifying your identity, communicating with you, for billing purposes, and to perform our contract to provide Services to you. Account Information can be used to manage your Services. |
| Client Information | We collect the name, and contact information, of our clients and their employees with whom we may interact. | We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing. |
| Contact and Other Information | We collect contact information, such as your name, e-mail address, and, if you provide it, mailing and physical address, phone (or mobile) number, and zip code, as well as other basic details about you, including your date of birth. | We have a legitimate interest in contacting you. In some cases, we also use this information to perform our contract to provide you with Services and to comply with laws. |
| Cookies and first party tracking | We use cookies, which are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. | We have a legitimate interest in making our website operate efficiently. |
| Cookies and third party tracking | We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. | We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics. |
| Demographic Information | We may collect personal information, such as your age or location. | We have a legitimate interest in understanding our users and providing tailored services. |
| Email Interconnectivity | If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. | We have a legitimate interest in understanding how you interact with our communications to you. |
| Employment | If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment. | We use information about current employees to perform our contract of employment, or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and work force operations. |
| Feedback/Support | If you provide us feedback or contact us for support we will collect information such as details of queries, complaints, feedback or issues with your Account or our Service | We have a legitimate interest in receiving, and acting upon, your feedback or issues. |
| Investment Information | We collect information about investment trusts and/or entities that you are the contact for, including information about your spouse if they are an accountholder. | We have a legitimate interest in maintaining contact information related to your investment trusts or entities. In some circumstances, we also require this information in order to perform our contract to provide you Services. |
| Investor Information | We collect investor information, which may include income, net worth, entity name, pay slips, bank statements, tax forms, letters from a registered broker-dealer, SEC registered investment attorney, certified public accountant, incumbency certificate, officers certificate, and any other information you provide or documents you upload to the Account for verification. | We have a legitimate interest in collecting information about the investors that utilize our Services. In some circumstances, we also use this information to perform our contract to perform Services for you and in order to comply with law. |
| Mailing List | When you sign up for one of our mailing lists we collect your email address or postal address. | We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services. |
| Mobile Devices | We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores. | We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices. |
| Order Placement | We collect your name, billing address, shipping address, e-mail address, phone number, bank account information and credit card number when you place an order. | We use your information to perform our contract to provide you with products or services. |
| Partner Promotion | We collect information that you provide as part of a co-branded promotion with another company. | We have a legitimate interest in fulfilling our promotions. |
| Social Media | We collect information you share with us via social media. | We have a legitimate interest in understanding how users interact with us via social media. In some circumstances, we also collect this information based upon your consent. |
| Submitted Content | We collect photographs, videos, comments and other content that you submit to us. | We collect the information you provide us based upon your consent. |
| Surveys | When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. | We have a legitimate interest in understanding your opinions, and collecting information relevant to our organization. |
| Sweepstakes or contests | When you participate in a sweepstakes or contest we collect information about you which includes contact information to notify you if you are selected. | We have a legitimate interest in operating the sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws. |
| Website interactions | We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
| Web logs | We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. | We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. |
WHY WE COLLECT INFORMATION
In many situations, we have more than one legal basis for processing your information. For example, if you request a verification through our Service, we may collect your information to fulfill our contract with you, but we also collect your information as we have a legitimate interest or legal basis in maintaining your information for record keeping purposes. As a result, our collection and processing of your information is based in different contexts, upon different of those legal bases.
HOW WE COLLECT INFORMATION
We Collect Information through Our Interactions with You
We collect information from you, your client or spouse when:
- You interact with our Service;
- You request information about our Service;
- You sign-in or visit your Account and use our Service;
- You use a social media service, for example, our Facebook page or blog;
- You sign up for e-mails, mobile messages, social media, or other communications or notifications from us;
- Third parties send us information about you;
- You enter a contest or sweepstakes, respond to one of our surveys, or participate in a focus group; and
- You provide us with comments, suggestions, or other input.
We Collect Information Using Cookies and Other Technologies
In addition to collecting data directly from you, we may use cookies, tracking pixels/web beacons and or other technologies to receive and store certain types of information. “Cookies” are pieces of information that may be placed on your computer, tablet, or device for the purpose of facilitating and enhancing your communication and interaction with our Service.
We may use cookies and these other technologies to collect information as follows:
- Category 1: Strictly necessary. These cookies and other technologies are strictly necessary to enable you to use our Service, for example accessing your Account and providing you the Service you have requested.
- Category 2: User choices. These cookies and other technologies allow us to remember the choices you have made, for example your user name, language used, or country. They may be used for user preferences purposes.
- Category 3: Third-Party Analytics. These cookies and other technologies are placed by our third-party partners for web analytics purposes. Examples of these cookies and other technologies include Google Analytics and Adobe Analytics. You can opt out of Google Analytics by following the instructions provided at https://tools.google.com/dlpage/gaoptout.
Specifically, in addition to strictly necessary cookies, we may use the following third-party cookies:
| Name | Provider | Expiration |
|---|---|---|
| 1P_JAR | www.google.com | 30 days |
| NID | www.google.com | 6 months |
| DV | www.google.com | 1 minute |
Generally, you may stop or restrict the placement of our cookies on your computer by adjusting your web browser preferences, but please note that this may impact your ability to access your Account and use our Service, for example, some Cookies we place are to verify your identity and are therefore an important aspect of maintaining the security of your account.
We Collect Information from Other Sources
We may also obtain information from third parties, including business partners, affiliates, associated trust entities, and publicly available sources, that can enhance and add to our information about you (e.g., adding address information). This may improve our ability to contact you and improve the relevancy of our marketing by providing better recommendations or special offers that we think may interest you.
HOW WE PROTECT THE INFORMATION WE COLLECT
No method of transmission over the Internet, or method of electronic processing or storage, is fully secure. While we maintain reasonable security measures to protect the confidentiality and security of information we hold, we cannot guarantee the security of your information. In the event that we are required by law to inform you of a breach of your information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
If you register for an Account, you will be asked to create a password. You are responsible for maintaining the confidentiality of your password and for any access to or use of your Account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us immediately of any unauthorized use of your password or Account.
Our Affiliates and Associates
We may share your information with our corporate affiliates and associates (e.g., parent company, sister companies, associated trust entities, subsidiaries, joint ventures, or other companies under common control); provided, however, that, in the event an issuer shares any investor’s personal information with us, we shall not use an investor’s personal information provided to us by an issuer for marketing purposes. We have a legitimate business interest to share data with our group as it allows us to better understand the performance of our Services and how to offer and improve our product offerings across the group. It also assists us with finding operational efficiencies (such as financial efficiencies through sharing IT infrastructure), making use of group level software solutions and improving our technological offerings which form an integral part of our Service.
Service Providers
We may share your information with third parties that provide services to us. Among other things, these third parties help us with the administration, operation, and marketing of the Service and our product offerings across our group. This includes hosting, communications, printing, marketing, data enhancement, technical support, payment or transaction processing, and fulfillment of services. In some cases, we share your information with these third parties and they may in turn use your information for their own purposes. Such use is not governed by this Privacy Policy and they may only undertake such communications with you for marketing proposes if they have established a lawful basis for processing. Please note that such organizations may from time to time need to contact you with service communications, such as details of system upgrades or security patches, we do not send these notifications and it is your responsibility to ensure that you have reviewed any applicable terms and privacy policies that apply to such services or plug-in.
Other Third Parties
Subject to the limitation on an investor’s personal information set forth above, we may share your information with nonaffiliated third parties, for example, for them to develop their own products or market to you, where we and they have established requisite legal permission(s) to do so. Such use is not governed by this Privacy Policy.
Legal Requirements
We may disclose information when we believe disclosure is appropriate to comply with the law, to enforce or apply applicable terms and conditions and other agreements, or to protect our rights, property or safety or the rights, property or safety of our affiliates or associated trust entities, users, or third parties. For example, we may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
When You Direct Us
We may share your information at your direction or request, either through your Account, our Service, or otherwise.
With Your Consent
We may ask if you consent to share your information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and may share your information with your consent.
Business Transfers
If another entity acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. We also may retain a copy of that information.
HOW LONG WE RETAIN YOUR INFORMATION
We will retain your information for as long as necessary for the purposes described in this Privacy Policy and in accordance with the following principles:
- For the duration required pursuant to a legal obligation;
- For the period required by applicable law and regulations, for the activities relating to the service; or
- For the duration of legal proceedings and the related limitation periods, for processing activities necessary to protect against legal liability and enforce our rights.
INTERNATIONAL DATA TRANSFERS
Our Service is controlled and operated from facilities within the United States. Nonetheless, where required and possible, we take steps to treat your information using the same privacy principles that apply pursuant to the law of the country in which we first received your data.
If you are located in the European Union (“EU”) or your data is otherwise governed by EU privacy laws, we may transfer your personal information to countries outside the European Economic Area (“EEA”) for processing in accordance with this Privacy Policy and as permitted by applicable laws. Where this is the case, we will ensure that any transfer is necessary for the performance of a contract between us or a contract in your interest, or any entity receiving your information is subject to laws ensuring an adequate level of data protection as determined by the relevant EEA regulatory authority or will ensure that an adequate level of data protection will be available on the basis of standard contractual clauses that will allow you to directly enforce your rights as a third-party beneficiary.
WHAT CHOICES AND RIGHTS YOU HAVE REGARDING YOUR INFORMATION
We offer you the rights and choice described in this section. Note that if your information was collected by another party under their privacy policy, we may refer you to that party in order to exercise the choices regarding your data.
Rectify Your Information
We rely on you to update and correct your information. Note that we may keep historical information in our backup files as permitted by law. If our Services do not permit you to update or correct certain information, contact us at the address described below to ask us to rectify information that you think is inaccurate or incomplete.
Opting Out of E-mail, Telephone and Text Message Marketing
When we send you promotional emails based on your consent or as permitted by applicable laws, you have the right to unsubscribe. You also have the ability to unsubscribe to promotional e-mails by following the unsubscribe instructions in e-mails. Please allow us up to 10 business days to implement your request to unsubscribe. Note that even if you decide not to receive promotional emails, we may still send you service related communications.
We may distribute mobile coupons and text messages to your mobile device if you have requested this information via an opt-in request. You may opt out of receiving text messages and mobile coupons via the texts you receive.
If you do not wish to receive promotional telephone communication from us, call us at (818) 925-6701 to opt out. This opt out does not apply to operational communication, for example, confirmation of delivery address.
Additional Rights for Individuals Located in Certain Jurisdictions
In some circumstances we may be subject to additional data protection laws that give you additional data protection rights, for example, if you are located in certain jurisdictions (for example, in the EEA). To the extent required by these applicable laws, we will grant you the following additional rights, provided we can adequately verify your identity:
- Access to Your Personal Information. You may request access to your personal information by contacting us. If permitted and required by law, we will grant you reasonable access to the data that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of data (if any) we share with third parties, affiliates or associated trust entities for direct marketing.
- Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of data, or request that we delete your personal information by contacting us at the address described below. If permitted and to the extent required by law we will grant a request to delete personal information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, in pursuit of a legal action, to detect or monitor fraud, to resolve disputes, or to enforce our agreements with you.
- Objection to Certain Processing. You may object to our use of your personal information by contacting us. For example, for individuals located in the EU (or where EU data protection law otherwise applies) you have the right to object to direct marketing and in some circumstances the right to object to certain automated processing operations.
- Right to restrict processing. At your request, we will limit the processing of your information in certain circumstances, for example where: (i) you dispute the accuracy of your information; (ii) your personal information was processed unlawfully and you request a limitation on processing; (iii) we no longer need to process your information but you require your information in connection with a legal claim, or (iv) you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
- Right to data portability. Where permitted and required by law, you have the right to receive your information in a structured, commonly used, and machine-readable format in certain circumstances.
- Revocation of Consent. You may revoke any prior consent for the processing of your personal information. If you revoke your consent, then we may no longer be able to process your personal information or provide that part of the Service that relies upon such consent. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so.
ADDITIONAL INFORMATION
Important Notices and Transactional E-mail
From time to time, we may send non-commercial electronic email messages with important information about us or our Service to your email address. Please note that any opt-out will not apply to other communications that will be provided to you or any entity or trust that you are the contact point for in relation to your transactions with us, in agreement with us, or where required by law.
Third Party Websites and Services
Our Service contains links to other websites and services not maintained by us or our affiliates or associates. In addition, other websites and services may also reference or link to our Service. Use of such third-party websites is subject to the terms of use and privacy policies of those third parties. We do not control the privacy policies or practices of these third-party websites. We encourage you to be aware when you enter or leave our Service, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.
Compliance with State and Federal Laws
Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain certain of your information to be in compliance with applicable federal and state laws regarding recordkeeping, reporting and audits.
Do Not Track
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.
Privacy Policy Revisions
We may change this Privacy Policy and our information collection, use, and sharing practices over time. To the extent that our Privacy Policy changes in a material way, we will notify you in advance of the changes taking effect. Any modified Privacy Policy will supersede the revised Privacy Policy and, unless otherwise stated, will apply to the information we maintain about you.
HOW TO CONTACT US REGARDING THIS PRIVACY POLICY
If, at any time, you have questions or concerns about this Privacy Policy, please contact us through our contact page or at:
support@verifyinvestor.com
6136 Frisco Square Blvd, Suite 400, #414, Frisco, TX 75034
818.925.6701
If you are not satisfied with our response, and are in the EU, you may have a right to lodge a complaint with your local supervisory authority.
UPDATES
This Privacy Policy may be updated to reflect changes to our processing. In the event there is a material change to this Privacy Policy we will make revised notices available to you and place a notice in our offices. If you would like to be provided with a prior copy of our Privacy Policy please contact us via one of the methods above.