VerifyInvestor

Privacy Policy

VERIFYINVESTOR.COM PRIVACY POLICY

Effective Date: October 26, 2019

Thank you for your interest in VerifyInvestor.com. Verify Investor, LLC (“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:

We also automatically collect your IP address and other information about how you use the Service, the areas of the Service that you visit, as well as information about your computer or mobile device.

WHY WE COLLECT INFORMATION

Purposes for Processing

Depending on the use of the Service, we process your information for the following purposes to: (1) set up an Account; (2) process any documents you upload as part of the Service to verify your status as an accredited investor, qualified purchaser, or qualified client or other diligence or verification services; (3) provide personal information to the parties who wish to obtain verification of your accredited investor status and other third parties as necessary to provide the Service; (4) ensure the security of your Account; (5) enable us to respond to you when you contact us; (6) generate internal reports and conduct analytics about the use of the Service; (7) deliver messages like special offers, updates, newsletters, customer service, and service announcements; (8) serve you advertisements when you visit the Service; (9) conduct surveys and to publish the results thereof; (10) ensure legal compliance and exercise our legal rights, such as enforcing our agreements with you; (11) protect you and other users of our Service and third parties; (12) carry out certain internal functions, such as information management, account processing, client services, or other data collection relevant to our business; (13) with our third party service providers who provide us with support services (14) investigate and help prevent potentially unlawful activity or activities that threaten the integrity of the Service; (15) protect and defend our rights or property or the rights or property of others, as required by courts or administrative agencies; (16) in connection with a financing, sale, merger, or reorganization of our business or assets; and (17) with non-affiliated third parties, so that they may market their products and services to you, where they have a lawful basis to do so. Notwithstanding the foregoing, 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.

Legal Bases for Processing

We process your information based on the following legal bases for each of the purposes listed (1)-(17) above. We have listed the relevant purpose against each of these legal bases.

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:

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:

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.

HOW WE SHARE THE INFORMATION WE COLLECT

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:

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:

Your California Privacy Rights California residents have the right to receive, once a year, information about third parties with whom we have shared information about you or your family for direct marketing purposes during the previous calendar year, and a description of the categories of the personal information shared. If you are a California resident and wish to make such a request, please send an email to support@verifyinvestor.com and include the phrase “California Privacy Request” in the subject line, and provide us with your name, address, and email address. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. We will respond to you within thirty (30) days of receiving such a request. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

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
13701 Riverside Drive, Suite 300, Sherman Oaks, CA 91423

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.