Effective October 1, 2018
"Cookies" means small pieces of data stored on a User's device.
"Personal Information" means non-public information that personally relates to or identifies a User, including, without limitation, a User's name, user name, password, age, gender, e-mail address, postal mailing address, zip code, home/mobile telephone number, Social Security number and/or taxpayer identification number, photo, date of birth, net worth, income, status as an accredited investor, investment objectives, investment experience, assets and income, and other similar information.
"Usage Information" means data collected on our Website, including, without limitation, website pages viewed, sites visited before visiting our Website, frequency of visits, clickstream data, browser type, operating system, organization name, articles, internet connection speed, presentations viewed, time spent viewing pages of our Website or using certain features of our Website, demographic data such as server locations, clickstream data, location services, server location, Cookies existing on your computer, search criteria used and results, date and time of access or visits to our Website, frequency of visits to our Website, connection speed, and other information that does not specifically identify a User.
"User Information" means both Personal Information and Usage Information.
Information We Collect
Information you Provide us
We receive information about you if you choose to provide it to us, such as when you register for and create an account on our Website. This information primarily consists of Personal Information. If you choose to invest in a business through our Website, we will collect payment information from you, such as financial account information or payment card information, and we may collect information to verify your income, such as a bank statement or W-2 form. Please note that we do not store your payment card information, but we do store other financial information. If you choose to add an investment entity to your account, we will also collect information about the entity.
When you Visit our Website
We automatically collect Usage Information when you use our Website or the Services.
Information from Other Sources
In order to provide the Services on our Website, including verifying your identity and other information you provide us, we collect information about our Users from third parties and combine it with other information we receive from or about our Users.
Our Pledge to You
We are required by law and regulatory bodies to ask for certain information in order to provide our Services to you. Alumshares makes commercially reasonable efforts to maintain the confidentiality, integrity and security of User Information. Keeping User Information secure, and using it only as our Users want us to, are matters of principle for all of us at Alumshares. Except as you may otherwise expressly approve:
- We will limit the collection and use of User Information to what we believe would be useful to service User accounts, administer our business, and/or to tell Users about our Services;
- We will restrict employee access to User Information to those who needs to know in order to provide Services to Users;
- We will educate our employees according to our internal policies to reinforce the importance of confidentiality and User privacy;
- We will maintain commercially reasonable and customary security standards and procedures to protect User Information; and
- We will respond quickly to User request to correct inaccurate information.
How and Why We Gather Information
Use of our Website
We also collect information when you post questions or comments on our Website, send or receive direct messages from other Users, or when you contact us, including via e-mail, phone, or social media.
We or our service providers may also collect web surfing data related to your use of the Services. This may be accomplished by using Cookies, web beacons, page tags or similar tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Website. 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 Services.
Social Media Features
How Information Helps Both You and Us
Information about you and your accounts plays a key role in our ability to service your accounts and administer our business. For example, we use User Information to:
- Provide you with the Services available through our Website;
- Establish and set up your account, issue an account number, and maintain your transaction history;
- Respond more accurately and efficiently to your requests;
- Identify opportunities to give you more convenience and control by developing new services that may benefit you;
- Verify your identity and contact information to help protect you and Alumshares from fraud; and
- Comply with certain legal and regulatory requirements.
We generally use the User Information that you provide or that we collect to establish and enhance our relationship with you, and to operate, maintain, enhance, and provide the Services and our Website. We may use such information to periodically provide you with information, newsletters or offers about features and services available through our Website that may be of interest to you. We may also send information or offers to groups of Users on behalf of other Users or third parties. However, you will have the option to opt out of receiving such information. We use aggregated information provided by or collected from our Users to understand and analyze the usage trends and preferences of our Users, to improve the way the Services and our Website work and look, and to create new features and functionality. We may use aggregated information about our Users' investments to generate statistics and maps that we deem helpful in the provision of the Services or any part thereof. We do not and will not sell analytics about our Users without written consent from each User.
Sharing Your Information with Others
You are permitted to share your account with all other Users and/or only with such other Users as are designated by you. You are not required to share your account or any other information with other Users. If you do share your account, anyone you designate will be able to see your information.
Businesses that you Invest in
If you indicate an interest in making an investment through our Website, we are permitted to notify the party or parties offering the investment of your interest and may notify other Users with whom you have chosen to share information. By indicating an interest in an investment and/or sharing your account with other Users, you consent to this disclosure of your Personal Information. We may also collect and store information, which could include Personal Information and Usage Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.
We use service providers to provide certain services to us, such as analytics services, fraud detection, payment processing, and advertising and marketing services. We only provide our service providers with the information necessary for them to perform these services.
How and Why Alumshares Discloses Your Information to Third Parties
We limit the sharing of User Information outside Alumshares. We do not sell, license, lease, or otherwise disclose your User Information to third parties; provided, however, that we may disclose your User Information when such disclosure is legally required or appropriate pursuant any court orders, subpoenas or any regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies, and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
To help us improve the Services, we may engage third parties to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business. Use of any User Information we share with these third parties is limited to the performance of the task that we request. The third parties with whom we share User Information are required to protect it in a manner similar to the way we protect your User Information.
Publicly Available Information
We may make certain automatically collected information about your interactions and activities on the Services, such as the business or investment areas of interest to you or that you have invested in, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users. We may also disclose your Personal Information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.
We further reserve the right to disclose any of your Personal Information as we believe appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Website or network, to assist government enforcement agencies, to protect the security or integrity of the Services, or to protect the rights, property or personal safety of Alumshares, its Users, or others.
Change of Control
Any successor in interest to our business would acquire the information we maintain, including Personal Information, and may alter the terms of this Privacy Notice. Alumshares does not and will not sell any of your Personal Information, including your Usage Information, to any third party for purposes of advertising, soliciting, or telemarketing. We may, however, have to disclose your Personal Information, including Usage Information, to other companies or entities in the event that Alumshares may be sold or is sold to another company or entity. In that case, your Personal Information, including your Usage Information, may be sold or transferred to such acquiring company or entity.
Keeping Information Safe
We limit access to your Personal Information to those employees who have a legitimate business need to access such Personal Information to provide you with the Services. In keeping with industry standards and practices, we maintain commercially reasonable physical, electronic and procedural safeguards and controls to protect your Personal Information. The Website is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your Personal Information. Users are required to identify and authenticate themselves prior to accessing restricted portions of the Services. Generally, identification and authentication take place through the use of your user name and a password. You are responsible for keeping your password confidential.
We have security standards and procedures in place designed to prevent unauthorized access to your accounts and Personal Information. A key part of this process helps ensure that all Personal Information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your Personal Information changes, notify us at firstname.lastname@example.org immediately. The transmission of information via the Internet is not completely secure, and for this reason we cannot guarantee the security of information sent to us electronically. As a result, while we strive to protect User Information, we cannot and do not guarantee or warrant the security of information collected or otherwise obtained by us in connection with our Website. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through our Website and/or the Services in the event of a security breach.
We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from us, you may unsubscribe completely by emailing us at email@example.com. Please note that opt-out requests may take up to forty-eight (48) hours to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.
You will be able to modify the information concerning your account by visiting your account page and editing any information you wish to change. You will be able to change your e-mail address, password, contact information, or other login information by visiting your account's settings page subject to our Website policy. If you wish to delete your account or need help modifying account information, please contact us at firstname.lastname@example.org. We will require up to forty-eight (48) hours to process such requests. Through your account settings you will be able to set certain preferences and permissions regarding the visibility of your information, including Usage Information or Personal Information, to others.
Reviewing, Changing or Correcting Information
An Ongoing Commitment to Your Privacy
Our Website and the Services are not intended to be accessed and/or used by anyone located or residing outside of the United States. No one located or residing outside of the United States is allowed to access and/or use our Website or the Services, provide any Personal Information or receive our e-mail distributions. We do not knowingly solicit or collect Personal Information from anyone located or residing outside of the United States. If you believe that anyone located or residing outside of the United States has disclosed Personal Information to Alumshares, please report this to us immediately by emailing us at email@example.com.
If Alumshares learns that Personal Information has been collected from anyone located or living outside of the United States, then Alumshares will take the appropriate steps to delete this information.
Our Website is not intended for use by minors, especially those under eighteen (18) years of age. No one under eighteen (18) years of age is allowed to use our Website, provide any Personal Information or receive our e-mail distributions. We do not knowingly solicit or collect Personal Information from anyone under eighteen (18) years of age. If you believe that a minor has disclosed Personal Information to Alumshares, please report this to us immediately by emailing us at firstname.lastname@example.org.
If Alumshares learns that Personal Information has been collected from a minor, then Alumshares will take the appropriate steps to delete this information.