PRIVACY POLICY

This Privacy Policy specifies the personal information that we ask you to provide and how we treat this information. This Privacy Policy is part of our Terms of Use, and all the terms and conditions set forth in the Terms of Use also apply to this Privacy Policy. Capitalized terms that are not otherwise defined in this Privacy Policy have the meanings given to them in the Terms of Use.

IF YOU DO NOT UNDERSTAND OR DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT USE THE SITE

YOUR CONSENT

You will be deemed to have consented to the terms of this Privacy Policy by using the Site in any way, even just browsing. We may also ask you to indicate your consent more formally by checking a box or otherwise taking affirmative action.

CHANGES TO PRIVACY POLICY

We might change this Privacy Policy from time to time. If you have consented merely by using the Site, then we will not necessarily notify you of the changes. If you have consented more formally, as described above, then the changes will not become effective until we have asked you for, and obtained your consent.

PERSONAL INFORMATION WE COLLECT

We collect a variety of personal information to operate the Site and provide the Service, including:

• Your name, address, phone number, email address, birth date, and other personal information.
• Financial information, including your social security number, income, and net worth.
• Copies of your tax returns, brokerage statements, W-2 forms, and other financial documents.
• Your user name and password.
• Information to confirm your identities, such as a completed electronic check transaction or a credit report.
• Your W-9 form.
• Information to confirm your place of residence.
• Information about your use of the Site.
• Information about your computer configuration.
• Information to confirm your relationship with other parties associated with the Site.
• Information about your bank accounts or other sources of payment.
• Your IP address.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to:

• Verify that you are permitted to use and invest through the Site.
• Keep track of your investments.
• Guard against fraud.
• Comply with applicable law.
• Answer your questions.
• Protect our rights.
• Send to third parties at your request.
• Process your transactions at the Site.
• Determine whether your computer information is compatible with the Site.
• Keep track of your use of the Site.
• Send you information about your investments.
• Notify you of other possible investments in which you might have an interest.
• Analyze the use of the Site.
• Improve the Site.
  Send you information about the Site.
• Send you materials about us.
• Use for other purposes we disclose to you.

WHAT WE PROVIDE TO THIRD PARTIES

We do not provide any third party with any of your personal information except in these situations:

• We use third parties to perform services for the Site, such as hosting services, electronic signature providers, electronic payment service providers, and services that verify the qualification of investors. Each of these third parties will need some of your personal and/or financial information to perform their services.
• If you invest, we will identify you on tax returns and other government forms.
• We will provide information if we believe we are required to do so by law.
• If our company is sold, all information will be transferred to our successor.
• If you choose to participate in discussions or messages boards at the Site, other users will be able to see your name (but not any other personal information) and any other information you voluntarily provide to be seen.

We do not provide any of your personal information to third parties for marketing purposes.

OUR AFFILIATES

We may provide information to one or more of our affiliates, meaning a company that we control or that is under common control with us. All of our affiliates will also be bound by the terms of this Privacy Policy.

NOTIFICATIONS AND COMMUNICATIONS FROM US

We will send you email notifications from time to time. For example, we may send you emails:

• To confirm your registration.
• To provide you with legal notices.
• To notify you of new investment opportunities.
• When the online profile you created is changed.
• To ask you to participate in surveys, or otherwise provide feedback.
• To confirm your investment in a project.
• To ask you for information.

You may also receive emails from third-party providers.

MODIFYING AND DELETING INFORMATION

To modify or delete your personal information, please log in and update your profile. We may retain certain information as required by law or for necessary business purposes.

HOW WE PROTECT YOUR INFORMATION

We have put in place systems designed to protect your personal information, including:

• We employ a secure channel, using Secure Sockets Layer encryption, the standard for secure Internet network connections, to protect information exchanged over the Internet between your web browser and our servers.
• Our employees and agents are required to abide by this Privacy Policy.
• We use automated tools to monitor network traffic to identify unauthorized attempts to upload information, change information, or otherwise seek to gain unauthorized entry into our systems.
• We take additional steps to protect especially sensitive information.
• In general, we use the same level of data encryption that is used by banks.

Nevertheless, no security system is perfect. We cannot guarantee that your personal information will remain private.

COOKIES, ETC.

A cookie is a small amount of data sent to your browser from our computer. We use cookies to provide you with tailored user experience and to make it easier for you to use a website upon a future visit. You may set your browser so that it does not accept cookies, although this would affect the usability of the Site.

We or our service providers (such as Google Analytics) may collect data related to your use of the Service, including which of our pages you access, the frequency of such access, and your product and service preferences. This data collection may be accomplished by using cookies, web beacons, page tags or similar electronic tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, clickstream data, operating system and the dates and times that you visit the Site. Web surfing data and similar information may be used for administrative purposes, to assess the usage, value, and performance of our online products and services, and to improve your experience with the Service. As with cookies, the web surfing information collected is aggregated, anonymous “clickstream” and transactional data, and is not associated with any users as individuals.

If you would prefer not to see advertising based on your personal preferences, you can change your personal settings in Google (look for “Ad Settings”) or visit the website of the Network Advertising Initiative located at:

http://www.networkadvertising.org/choices/#completed

THIRD PARTY SITES

You might navigate to websites maintained by third parties by clicking on a link from our Site, including through a banner advertisement. Once you leave our Site, the terms of this Privacy Policy no longer apply and we have no control over the collection or use of personal information you provide to such websites.

NOTICE OF PRIVACY RIGHTS TO FLORIDA RESIDENTS

Florida law requires that we provide you with a summary of your privacy rights under the Florida Online Privacy Protection Act (the “Florida Act”) and the Florida Business and Professions Code. The Florida Act requires us to inform you, at your request, (1) the categories of personal information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The Florida Act further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or standard mail. When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with marketing partners. The request should be sent to the attention of our legal department, and labeled “Florida Customer Choice Notice.” Please allow 30 days for a response. There is no charge.