We do not knowingly collect or solicit Personal Information directly from anyone under the age of 13 or knowingly allow such persons to register for the Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any Personal Information on their own behalf to us or on the Services. In the event that we learn that we have collected Personal Information from a child under age 13 (and not from a Parent on that child’s behalf), we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 that was not supplied by that child’s Parent, please contact us at email@example.com.
II. WHAT INFORMATION DOES COMPANY COLLECT?
A. Information You Provide to Us:
We receive and store any information you provide to us. For example, we may collect Personal Information such as your name, email address, and user name. We may also collect credit card information if you choose to use one of our paid service options. You can choose not to provide us with certain information, but then you may not be able to register with us or take advantage of some of our Website’s features or other Services.
B. Information Collected Automatically:
When we collect Usage Data, we use this data internally to analyze user activity, which allows us to better optimize or improve user experiences on our Website and in connection with our other Services and to recommend content that may be of interest to you and to provide a more focused user experience generally. In addition, such user analysis allows us to generate reports with aggregated results such as what firms are most popular among our users and what investment styles are trending.
C. E-mail and Other Communications:
We may contact you, by email or other means; for example, we may communicate with you about your use of the Website or any of the Services or send to you general industry newsletters or emails with personalized news updates. Also, we may receive a confirmation and/or other information when you open an email from us. This confirmation and/or other information helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please indicate your preference through your account settings through your Services account. Please note that if you do not want to receive legal notices from us by email, those legal notices will still govern your use of the Website or any of the other Services, and you are responsible for reviewing such legal notices for changes.
III. WILL COMPANY SHARE ANY OF THE INFORMATION IT RECEIVES?
We share your Personal Information, including, without limitation, your credit card information, in personally identifiable form with third parties as described below.
A. Affiliated Businesses and Third Party Websites We Do Not Control:
In certain situations, businesses or third party websites we are affiliated with may sell items or provide services to you or otherwise interact with you through the Website and/or the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service or interaction. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service or other interaction relating to an affiliated website or business, please review all such policies of these affiliated websites or businesses.
We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you, for example, processing credit card payments. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us.
C. Business Transfers:
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.
D. Protection of Company and Others:
We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
E. Usage Data:
When we collect Usage Data, as described in Section II(B), we may share such Usage Data in aggregate form (as combined with Usage Data that we receive from our other users), and not in a manner that would identify you personally, for marketing or other business-related purposes. For example, we may share with other users or third parties reports with aggregated results such as what firms are most popular among our users and what investment styles are trending.
F. With Your Consent:
If authorized by you through the Services or otherwise, your Personal Information may be shared with third parties in personally identifiable form (e.g., as contact information in connection with the firm profile that you provide).
IV. IS PERSONAL INFORMATION ABOUT ME SECURE?
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Please remember that you control the information that you input, upload or otherwise provide to our Services and the data that is collected in connection with your subscription to our Services.
V. WHAT INFORMATION CAN I ACCESS?
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- email address
- user profile information
- certain other content you have uploaded to the site
The information you can view, update, and delete may change as the Website changes. If you have any questions about viewing or updating information we have on file about you, please contact us at firstname.lastname@example.org. We will respond to all such requests within 30 days after receipt thereof. If you request that any of your Personal Information be deleted from our records, there may be a brief delay in our processing that request, while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that any of your Personal Information be deleted, we reserve the right to terminate and/or limit your access to the Services. While you may request that we delete certain Personal Information, we may continue to utilize and disclose such information in aggregate, non-personally identifiable form as provided above.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to Boston Illiquid Securities Offering Network, Inc., 205 Portland Street, Suite 200, Boston, MA 02114.
VI. WHAT CHOICES DO I HAVE?
As explained above, you can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of the features of our Website and/or other Services.
You may be able to add, update, or delete information as explained in Section V above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by writing to email@example.com. Please note that some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. In the event that your account is deleted by you or the Company or your subscription to the Services terminates or expires, following such deletion, termination, or expiration, you will no longer be able to access any of your account information, the information that you upload or receive through your use of the Services or other Personal Information that we hold in our records following the date the account is deleted.
VIII. QUESTIONS OR CONCERNS
If you have any questions or concerns regarding our privacy policies, please send a detailed message to firstname.lastname@example.org, and we will try to address your concerns.
Effective Date: June 8, 2014