Startfund Privacy Policy

This Privacy Policy was last updated on June 24, 2021

About this Policy

Startfund, INC. provides an intermediary technology platform.
This privacy policy (“Privacy Policy”) describes how Startfund INC. dba Startfund (together “Startfund,” “we,” “us,” and “our”), collect, use and disclose any personal information provided to us through our website, mobile application, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels. A “user” or “you” refers to anyone who accesses, browses, or in any way uses the Services. By using the Services, you acknowledge and consent to our practices described below.

Personal Information We Collect and Process

We collect and determine the purposes and means of the processing of certain information that may personally identify you (“Personal Information”) when you use our Services, like when you sign up for an account, make an investment, or otherwise interact with or communicate with us. We may also receive, and process Personal Information controlled and stored by third parties with your consent.

Personal Information we collect includes, among other things, your:

 Identity data such as your full name, date of birth, gender, social security numbers, and other data on government-issued identification documents.

Contact data such as your email address, mailing address, and telephone numbers.

Financial data such as your bank account information, card payment details, credit reports and information about your income and net worth (“Financial Data”).

Profile data such as your username and password, investments made by you, your investment experience, your educational and/or professional history, your employment status, your marital status, your investor quiz results, and your interests, preferences, and feedback. Usage information such as information about how you access and use our Services, your actions on the Services, including your interactions with others on the Services, photos or media you upload to the Services, comments and posts you make in our public discussion forums, and other content you may provide.

Technical Data such as IP (internet protocol) address, ISP (internet service provider), the web browser used to access the Services, the time the Services were accessed, which web pages were visited, operating system and platform, a mobile device-type identifier, and other technology on the devices you use to access our Services (“Technical Data”). We may also access your photo and cameral roll and Apple Face ID through our mobile application with your permission.

Additional information such as information that you submit via job applications, customer support, or other similar means and any other information you provide to Startfund.

In order to invest using the Services, you will need to register a user account. When you register a user account, we will collect certain Financial Data from you. Please note that we do not store Financial Data such as your bank account information and credit card details, but we do store other Financial Data, such as net-worth and income representations. If you choose to add an investment entity to your account, we will also collect information about that entity, such as the date of formation, tax identification number and state or country of formation, in addition to the Personal Information listed above.

The decision to provide Personal Information is optional when using the Services; however, if you decide not to register an account or provide the necessary Personal Information or Financial Data to validate your account or fulfill your obligations when using the Services, you may not be able to use certain features of our website or the Services

Even if you do not register a user account, we may collect Technical Data from you. Technical data may allow us to determine more specific information about you, such as the operating system of the device used to access the Services and your approximate location. We also use third-party analytics services to provide us with a clearer picture of how you use the Services, such as where you click on our website, non-sensitive text entered into our website, and mouse movements.

Third-Party Sites

We collect and determine the purposes and means of the processing of certain information that may personally identify you (“Personal Information”) when you use our Services, like when you sign up for an account, make an investment, or otherwise interact with or communicate with us. We may also receive, and process Personal Information controlled and stored by third parties with your consent.

We process Personal Information provided to us from third-party sites when you register on our website or link your user account to third-party sites such as Twitter, Facebook, Apple or banking institutions. Examples of Personal Information a third-party site may control and, with your consent, share with Startfund include your name, your email address, your phone number, your mailing address, your government issued identification document, your tax identification number, and your Financial Data.

This Personal Information is not held on Startfund’s systems but is stored by and controlled by the third-party site in accordance with the terms and conditions of their relevant policies. We are not responsible for the maintenance or security of Personal Information stored and controlled by any third-party sites. For information on how a third-party site manages the information your share with that third-party site, please read that third-party site’s privacy policy and terms of use.

You may be able to revoke our access to your account on the third-party sites by updating the appropriate settings in the account preferences of the respective third-party sites. You understand that certain Services may not be available to you if you choose to remove our access to your account with the third-party sites.

Cookies and Other Identifiers

Similar to many digital platforms, we collect certain information through cookies, web beacons and other identifiers when you use our Services in order to provide, improve, protect, and promote our Services.

Cookies are small text files containing strings of alphanumeric characters that may uniquely identify your browser and let us help you log in faster and enhance your navigation through our website. A cookie may also convey information to us about how you use the Services (e.g., the pages you view, the links you click, how frequently you access the Services, and other actions you take on the Services), allow us to track your usage of the Services over time, and help us remember information about your visit. You can set your browser to not accept cookies, but this may limit your ability to use the Services.

Our website uses the following types of cookies:

Essential Cookies: These cookies are necessary to provide you with the Services available through our website.

Performance and Functionality Cookies: These cookies are used to enhance the performance and functionality of our website.

Analytics and Customization Cookies: These cookies collect information that is used either in aggregate form to help us understand how our website is being used or how effective our marketing campaigns are, or customize our website for you.

Advertising Cookies: These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interest.

Social Networking Cookies: These cookies are used to enable you to share pages and content that you find interesting on our website through third party social networking and other websites. These cookies may also be used for advertising purposes.

This Privacy Policy does not cover the collection of information by cookies or other methods by third-parties.

Other Identifiers

Web beacons or tracking pixels or clear gifs are another tool we employ. A tracking pixel is a transparent graphic image that is placed on a web page and, in combination with a cookie, allows us to collect information regarding the use of the web page that contains the tracking pixel. We use tracking pixels to trigger ads on participating websites based on activity tracked from the browser on a device used to visit our website. We also use them to tell when an advertisement we run on another website has been clicked on by Startfund visitors and use that information to judge which advertisements are more appealing to users.

Tracking pixels can also be used for third party web analytics and are used in HTML-based emails we send you to track which emails are opened and which links you click. The information collected from web beacons allows for more accurate reporting and improvement of the Services.

Although we do our best to honor your privacy preferences, we are not able to respond to “Do Not Track” signals from your browser or device at this time.

Information Provided in Public Forums

Some of the investment opportunities and related pages presented through the Services include publicly accessible discussion forums and other pages on our website or mobile application allow for public comment and discussion (collectively, “Public Comment”). You should be aware that any information you provide in these forums may be read, collected, and used by the general public. Information that you disclose in any of these forums is unencrypted, public information, and there is no expectation of privacy or confidentiality there. Please refrain from disclosing any Personal Information about yourself or anyone else in these discussion forums.

If you choose to post a Public Comment, we may use that Public Comment for marketing purposes, including through our social media. If you subsequently delete or make your Public Comment private, we will discontinue any subsequent use, but cannot retract previous re-publications of your previously posted Public Comment.

If you choose to make an investment public, a notice will be generated including certain details about that investment (a “Public Investment Notice”). We may use that Public Investment Notice for marketing purposes, including through our social media. If you subsequently make your Public Investment Notice private, or withdraw such investment, we will discontinue any subsequent use, but cannot retract previous re-publications of your previously posted Public Investment Notice.

How We Share and Use Your Personal Information

We may share Personal Information you provide to us with our affiliated entities (“Affiliated Entities”). If the Services you use are exclusively provided by one of our Affiliated Entities, you have the right to limit the other Affiliated Entities from contacting you for marketing purposes (“Affiliate Marketing”). Examples of Personal Information that we may share for Affiliate Marketing include your name, email address, phone number, net worth and income.

We provide Personal Information on a confidential basis to non-affiliated companies we engage as vendors or agents (“Third Party Providers”) and where we have a legal basis for sharing your Personal Information including (i) to facilitate the Services, such as with the companies we host, escrow agents, transfer agents, counsel, advisors, accountants, banks and other financial service providers, and (ii) to service our operations, such as maintaining software or servers, designing or implementing marketing initiatives on our behalf, or conducting audit or testing of any aspect of our operation or Services. Personal Information will be shared with such Third Party Providers only to the extent reasonably necessary for them to perform services for us or on our behalf and pursuant to confidentiality obligations, or in response to information requests, subpoenas, court orders, or legal process, from law enforcement agencies, self-regulatory organizations, state, federal and foreign regulators.

In addition to some of the specific uses of Personal Information we describe in this Privacy Policy, we collect and process Personal Information in order to: (i) deliver and improve our Services; (ii) manage user accounts and provide customer support; (iii) perform research and analysis about the use of the Services; (iv) develop, display, and track content and advertising tailored to your interests on the Services and other websites, including providing our advertisements to you when you visit other websites or mobile applications; (v) diagnose or fix technology problems; (vi) automatically update the Services; (vii) verify your identify and prevent fraud or other unauthorized or illegal activity; (viii) enforce or exercise any rights in our Startfund Portal Terms of Service ; (ix) provide users with statistics on how they use the Services relative to other anonymous users; (x) comply with applicable laws and legal obligations; and (xi) perform functions or services as otherwise described to you at the time of collection.

If you choose to make an account, we provide private messaging services between registered-users of our website and mobile application; while we do not monitor these messages, we will periodically select a few to review for compliance and audit purposes; therefore, you should assume any message you send through our website or mobile application may later be accessed by our staff or our regulators for compliance or audit purposes.

Note that in the ordinary course of internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. Startfund has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.

How We Transfer Your Personal Information

The Services are maintained in the United States of America. Personal Information that you provide us may be stored, processed and accessed by us, our staff, sub-contractors and third parties with whom we share Personal Information in the United States of America. We may also store Personal Information in locations outside the direct control of Startfund (for instance, on servers or databases co-located with hosting providers).

Although we welcome users from all over the world, by accessing the Services and providing us with your Personal Information, you consent to and authorize the export of Personal Information to the United States and its storage and use as specified in this Privacy Policy. Note the laws of the United States might not be as comprehensive or protective as laws in the country where you live.

Changes of Control

In the event a Startfund entity merges with another entity, is sold, or transfers its assets, we may disclose or transfer your Personal Information in connection with the negotiation and/or conclusion of such transaction.

Security and Storage of Your Personal Information

We follow industry privacy and data security standards as required under applicable data security rules and regulations (“Data Protection Laws”) to protect Personal Information submitted to us, both during transmission and once we receive it. When you provide us with Personal Information (such as Financial Data), we encrypt the transmission of that information using secure socket layer technology (SSL). We routinely review our security procedures to consider appropriate new technology and methods. Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is free of risk. Therefore, we cannot guarantee that your Personal Information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We disclaim all responsibility and liability for unauthorized access to our servers and systems.

We will retain your Personal Information for as long as your account is active or is needed to provide you the Services and may retain your Personal Information after you discontinue use of the Services provided there is a legal basis to do so. We will retain and use your Personal Information as necessary to comply with our legal obligations, including to meet our regulatory obligations, to resolve disputes, and to enforce our agreements.

Your Choices About Your Personal Information

Registering a user account with Startfund is voluntary and you do not need to create an account to use some of the Services. If you decline to submit Personal Information, Startfund may not be able to provide certain Services to you. If you elect to register an account with us, you may update or correct your account information and email preferences at any time by logging into your account. If you would like us to remove or amend your Personal Information from our database, please send a request to privacy{{env('SITE_NAME')}}.io; please note, as many of the Services we provide are regulated, we will not be able to remove Personal Information we are required to retain for audit purposes or where a legal basis exists for retaining your Personal Information.

When you sign up for our Services, we will send periodic emails to you regarding the Services or to tell you about new services we believe will be of interest to you. You may also subscribe to our blog and newsletter or sign up to hear about investing opportunities without registering a user account. You may choose to stop receiving our marketing emails by following the unsubscribe instructions included in these emails. If you do not wish to receive Affiliate Marketing, or any marketing, in general, you may always opt out by accessing your notification settings. You can also opt out of promotional email communications at any time by clicking on the unsubscribe link in any email you receive from us, or you can contact us at privacy{{env('SITE_NAME')}}.io.

User Access Rights

Under certain Data Protection Laws, you may have the right to request access to your Personal Information where your Personal Information is controlled by Startfund. Such rights may include:

· The right to request that your Personal Information be corrected.

· The right to request that your Personal Information be deleted from Startfund’s systems. This process is also referred to as the ‘right to be forgotten’. Startfund will comply with this request except where Startfund is required by law or regulation to keep your Personal Information. In such circumstances Startfund will advise you as to this legal or regulatory obligation.

· Where Startfund relies on your consent to process your Personal Information controlled by Startfund, you may have the right to withdraw such consent to further use your Personal Information.

· In certain circumstances, you may have the right to object to Startfund processing your Personal Information. For example, you may unsubscribe from marketing messages or blogs to which you consented and subscribed by following the unsubscribe link or instructions contained in such message or blogs.

· In certain circumstances, you may have the right to request that Startfund transfer Personal Information that you have provided to us to a third-party.

· The right to file a complaint with the local data protection regulator if you believe that Startfund has breached Data Protection Laws when using your Personal Information.

· The right to request access to Personal Information collected and controlled by Startfund by sending an email to: privacy{{env('SITE_NAME')}}.io.

Your California Privacy Rights

If you are a California resident, under the California Consumer Privacy Act (“CCPA”) you have additional rights regarding your Personal Information.

Right to Know. You have the right to know and see what Personal Information Startfund has collected about you over the preceding 12 months, including:

· The categories of Personal Information Startfund has collected about you;

· The categories of sources from which Personal Information is collected;

· The purposes for collecting your Personal Information in accordance with the Services;

· The commercial purposes for collecting your Personal Information;

· The categories of third parties with whom Startfund has shared your Personal Information; and

· The specific pieces of Personal Information Startfund has collected about you.

Right to Delete. You have the right to request that Startfund delete the Personal Information we have collected from you.

Deletion of your Personal Information is not an absolute right, however. There are exceptions under which we may retain your Personal Information and where we are not required to delete your Personal Information.

If you are a California resident and would like to exercise your rights in accordance with the CCPA, you may contact Startfund using any of the following methods:

· Via email at privacy{{env('SITE_NAME')}}.com; or

· Via our toll free California Personal Information Privacy Line at (213) 534-7757.

· We will respond to a California consumer requests for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

Special Notice Regarding Minors

Startfund respects the privacy of children of all ages and in particular recognizes the sensitivity of Personal Information concerning children under the age of 18 (“Minors”) and therefore provides this special notice to parents and legal guardians regarding the collection and use of Personal Information collected from Minors. The Services are not directed toward Minors. If you are under the age of 18, you may not use or access the Services. If we discover that a Minor has provided us with Personal Information, we will use commercially reasonable efforts to delete such Minor’s Personal Information from our system and close their user account. In some instances, we may be required to retain a Minor’s Personal Information in a limited capacity to comply with regulatory requirements.

How to Remove Cookie Tracking

We use tools, such as Google Analytics, to facilitate the collection of information. If you wish to disable Google Analytics from all websites you visit (not limited to our website), you can follow this link. The information gathered through the tools we employ is used to create reports about the use of our website and Services.

Please contact us if you wish to opt out of any of the tools we use. Please note, we reserve the right to add more tools or disable tools and will update this Privacy Policy to reflect these changes. Your request to disable such tools or your disabling of tools may limit your ability to access and utilize the Services.

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can obtain information about blocking and deleting cookies on certain web browsers via these links: Chrome, Firefox, Safari, and Edge.

Our website is protected by reCAPTCHA. The Google Privacy Policy and Terms of Service apply when you access Google’s website.

Changes to Our Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to this page. You should review this Privacy Policy regularly for changes. You can determine if changes have been made by checking the effective date at the top of this Privacy Policy. Your continued use of our Services following the posting of any changes to this Privacy Policy means you consent to such changes.