Privacy Policy

Introduction

 

This Privacy Statement covers Capital2Market Technologies, LLC (C2M) who is committed to respecting your privacy. 

 

C2M has developed this Privacy Policy (this “Policy”) to advise you of the ways in which C2M collects, uses, shares and protects your information. Any person accessing, browsing or otherwise using a website/platform where this Privacy Statement is posted (each, a “Site”) either manually or via an automated device or program, is a “User” for purposes of this Policy.

 

Relevant Legislation

 

Along with our business and internal computer systems, this website is designed to meet with the following national and international legislation with regards to data protection and user privacy:

As this site was designed to meet with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact our data protection officer (See How to Contact C2M below) for clarification.

 

 

User Consent to Policy

 

By accessing, browsing, or using a Site, each User acknowledges that he or she has read, understands, agrees and consents to the terms and conditions of this Policy. Each User consents to the collection, use, and disclosure of his or her information, including personal information, non-personal information, and anonymous browsing information (“Information”), pursuant to the terms of this Policy. If you do not consent to these terms and conditions, you should not access, browse, or use any Site or provide any Information to C2M via any Site.

 

Information Collected by C2M

 

A.        Personal Information

C2M may collect the name, title, company name, address, phone and/or fax number, job title, email address, birthday, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income information, information from your transactions with us such as your account balance and account usage, information obtained from others such as the Internal Revenue Service and credit reporting agencies, and other personal information provided by a User who contacts C2M or any of C2M’s representatives through a Site, via email or otherwise, submits a request for information, proposals, or to receive periodic updates, subscribes to C2M Insight, attends a webcast, live conference, or other C2M-sponsored or hosted event, participates in a discussion forum available through a Site, or engages in any other activity through a Site in which personal information is provided to C2M.

 

By submitting Information to C2M on or through the Site, a User acknowledges that he or she has read this Policy, understands it, agrees to its terms, and authorizes C2M to collect, use and disclose Information pursuant to the terms of this Policy.

 

B.        Non-Individually Identifying Browsing Information

Users can browse a Site without revealing personal information. In this context, C2M’s servers may collect certain non-individually identifying (i.e., anonymous) browsing information, such as your Internet Protocol address, your computer’s operating system, the name of the domain you used to access the Internet, the website you came from, and the website you visit next. This information is collected passively through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs, or other technologies, examples of which are explained further in Section C below. Anonymous browsing information is not used, nor is it intended to be used, by C2M to personally identify an individual.

 

C.        Passive Gathering of Information Electronically

C2M and any third parties that may advertise or provide other services on a Site may automatically and passively collect certain types of anonymous information whenever you use a Site or certain Site services or click on advertisements on a Site or in C2M’s periodicals, such as C2M Insight. If C2M or such third parties collect this anonymous information, it will be done passively through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs, and similar technologies as explained below.

 

HTML Cookies: C2M and certain third-party advertising partners may use “cookies.” When you use a Site, the pages you see, along with something called a “cookie,” may be downloaded to your computer, mobile device, or tablet (individually or collectively, “Equipment”). Cookies are small pieces of information that are stored by your browser on your Equipment. These cookies do not contain or collect any personal information, but may be used to deliver content on a Site specific to your interests and for other purposes, such as security and administrative functions. For example, cookies are used to store your preferences for certain types of information so that you do not have to input those preferences every time you use a Site. C2M and its third-party advertising partners do not as of the updated date of this Policy use cookies to deliver targeted advertisements to you when you are on a Site or third-party websites. Most web browsers automatically accept cookies, but you should be able to change your browser to limit or prevent cookies. Cookies in themselves do not personally identify the individual user of the Equipment, but rather the Equipment that is being used to access a Site. You may have the opportunity to set your Equipment to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. Different browsers may address cookies differently. If you set your browser to not accept cookies, it may result in certain personalized services not being provided to you when you use your Equipment.

 

Web beacons, Pixels and Clear GIFs: C2M and certain third-party advertising partners may use web beacons, pixels, and clear GIFs. These electronic technologies are transparent image files that, if used, allow C2M and its advertising partners to track website usage information, such as the number of times a website has been viewed and whether and when you have opened a HTML email, how many times the email was forwarded and which links in the email were clicked. Unlike cookies, these technologies are not placed on your Equipment. If used, this information will help C2M to improve a Site and C2M’s advertising materials and will help C2M’s advertising partners by measuring the effectiveness of such communications to you. These technologies may be used in association with cookies to understand how Users interact with a Site or advertisements.

 

How C2M Uses the Information

 

C2M uses the Information collected from Users to respond to Users’ questions and/or comments, market or provide products, services or information to Users, process Users’ investments, or provide related account status to the applicable User. Personal information, non-personal information, and anonymous browsing information may be used to gather broad demographic information used in marketing, promotion, analytics, or similar activities. This information may be aggregated to measure the number of visits, average time spent, page views and other statistics about Users of a Site. C2M also may use this Information to monitor Site performance and to make a Site easier and more convenient to use. C2M also may use Information collected from its Users to enforce its agreements with Users, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that C2M complies with applicable laws.

 

C2M Sharing of your Information

 

C2M only will share Information that it collects or receives regarding its Users with third parties under the following circumstances:

  • Consent: If C2M has a User’s consent to share any Information, it may do so.

  • Issuers: C2M may share certain information as it pertains to the issuer accepting your investment in order to conduct the offering in a legal and complaint manner.

  • Broker of Record (Broker/Dealer): C2M may share certain information with a registered broker/dealer of record in order to conduct the offering in a legal and complaint manner.

  • Agents: C2M may utilize other companies and individuals to perform functions on its behalf such as marketing new or additional C2M products and services, sending postal and electronic mail to Users, ID verification, accreditation/financial/credit verification, electronic document signing, payment storing and processing, escrow services, disbursement of funds, analyzing data, and providing customer service. These third parties have access to Information needed to perform their functions, but may not use it for other purposes.

  • Aggregate Anonymous Information: C2M may provide to others the aggregate statistics about our Users’ Site activity for purposes of marketing, promotion, analytics, or similar activities. None of these statistics will identify Users personally.

  • Protection of C2M or Others: C2M may disclose Information about our Users to others if C2M has a good faith belief that it is required or permitted to do so by law or legal process to respond to claims, to protect the rights, property or safety of C2M or others, or take action regarding illegal activities or suspected fraud, or in response to national security or law enforcement requests.

  • Business Transfers: In the event that C2M decides to sell all or part or its assets, C2M reserves the right to include Information among the assets transferred to the acquiring company.

  • Affiliates: C2M may share Information among its affiliates.

  • Conference and Roundtable Attendees. C2M may provide the names, titles, company names, addresses, phone information, and email addresses of conference or roundtable attendees to current, past, or prospective conference or roundtable attendees, exhibitors, sponsors, or co-sponsors.

C2M may be held liable for unlawful transfer of personal data to third parties.

 

Accessing, Changing or Deleting Your Personal Information

 

C2M allows you to correct inaccuracies in or make other changes or delete your Information by contacting C2M at (877) 787-7017 or sending an email to privacy@capital2market.com.  In addition, you may correct inaccuracies in or make other changes or delete your Information collected through C2M by updating your account in the Profile section of www.capital2market.com or sending an email to privacy@capital2market.com.

 

Data Integrity

 

Users are responsible for the accuracy of the Information they provide to C2M. C2M will use reasonable efforts to maintain the accuracy and integrity of Information.  

 

Data Hosting

 

C2M Transact is hosted on Google Cloud utilizing App Engine, Compute Engine, Cloud Storage and Cloud SQL;

  • Google Cloud Load Balancer takes advantage of infrastructure security features like Denial of Service (DoS) protection and centrally managed SSL/TLS support.

  • App Engine protects from security threats using firewall capabilities, Identity and Access Management (IAM) rules, and managed SSL/ TLS certificates.

  • Cloud SQL data is automatically encrypted and Cloud SQL is SSAE 16, ISO 27001, PCI DSS v3.0, and HIPAA compliant.

  • Compute Engine persistent disks are encrypted at-rest using keys protected by the central infrastructure key management system. All data written to persistent disk in Compute Engine is encrypted on the fly and then transmitted and stored in encrypted form. Google Compute Engine has completed ISO 27001, SSAE-16, SOC 1, SOC 2, and SOC 3 certifications.

  • Cloud Storage always encrypts your data on the server side, before it is written to disk. In addition, C2M utilizes sensitive data encryption that occurs before data is sent to Cloud Storage. Such data arrives at Cloud Storage already encrypted but also undergoes server-side encryption

 

 

Choices for Use or Sharing of Certain Information

 

C2M values your concerns about the privacy of your Information. Therefore, C2M offers you the opportunity to choose how certain of your Information is used by C2M.

Any emails sent by C2M that are subject to the U.S. CAN-SPAM Act will include an option to unsubscribe from further correspondence. Please note that even if you opt-out from receiving certain email from C2M, you will continue to receive transactional and/or relationship messages, such as messages confirming your investment, product purchase or your registration for an event.

As stated above, C2M may share names, titles, company names, addresses, phone information, and email addresses of conference and roundtable attendees with current, past, or prospective conference or roundtable attendees, exhibitors, sponsors, or co-sponsors. If you do not wish to receive further communications from these persons, you must contact them directly and make such a request. C2M is not responsible for how such third parties handle such Information.

 

Linked Internet Websites

 

The Site may provide hyperlinks, which are highlighted words or pictures within a hypertext document that, when clicked, take you to another place within the document, to another document altogether, or to other websites not controlled by C2M. These hyperlinked websites may contain privacy provisions that are different from those provided herein. C2M is not responsible for the collection, use, or disclosure of information collected through these websites, and C2M expressly disclaims any and all liability related to such collection, use, or disclosure.

 

Children’s Privacy Protection

 

No Site is directed towards children under 18 years of age, and C2M does not knowingly collect any information from children under 18 years of age through any Site. If you are under 18 years of age, you are not permitted to submit any information to C2M through any Site.

 

Security

 

Each Site has commercially reasonable security measures to protect against the loss, theft, misuse, and alteration of Information that is submitted to C2M and remains under C2M’s control. You should be aware, however, that C2M has no control over the security of other websites that you might visit or use, even when a link to those websites is available on or through the Site. If you share your Equipment or use Equipment that is accessed by the general public, remember to sign off and close your browser when you finish using the Site.

C2M wants you to feel confident using the Site; however, no system can be completely secure. Therefore, C2M makes no representations or warranties with regard to the sufficiency of its security measures. C2M shall not be responsible for any damages, including without limitation consequential damages, resulting from a lapse in compliance with this Policy as a result of a security breach or technical malfunction. Certain information may be transmitted to you by email. Although it is illegal to intercept or disclose such messages under U.S. Federal law, such transmissions are not secure. In addition, Users’ communications through a Site are, in most cases, viewed only by you and anyone to whom you address your message. As the operator of a Site, C2M may need to review or monitor your electronic mail and other communications through a Site from time to time as may be required by law. Therefore, you should not expect to have a right to privacy in any of your electronic communications through a Site.

In the event of a breach of the confidentiality or security of your personal information, C2M will notify you if reasonably possible and as reasonably necessary under applicable law so that you can take appropriate protective steps. C2M may notify you under such circumstances using the email address or addresses that it has on record for you. You should also take care with how you handle and disclose your personal information. Please refer to the U.S. Federal Trade Commission’s website for information about how to protect yourself against identity theft.

 

Amendments to Privacy Policy

 

C2M may occasionally update this Policy, as noted by the “updated date” at the beginning of this Policy. If C2M updates this Policy in a manner that allows it to collect, use, or disclose your personal information in a materially less restrictive manner than under a prior version of this Policy, C2M will provide you with prior notice of the pending update and seek your consent by posting notice on the Site or by contacting you using the email address or addresses that C2M has on record for you. C2M encourages you to periodically review this Policy to stay informed about its collection, use, and disclosure of your Information. Your continued use of a Site constitutes your agreement to this Policy and any updates.

 

Your California Privacy Rights

 

California law permits customers of C2M who are California residents to request certain information regarding our disclosure of their personal information to third parties for direct marketing purposes. At this time, C2M does not disclose personal information of “customers,” as defined under the California “Shine the Light” Act, to third parties for direct marketing purposes. If C2M changes this policy, it will update this provision and provide instructions on how you may make a request for details concerning such use of information.

 

Enforcement and Dispute Resolution

 

If you have any questions, complaints, or disputes regarding the manner in which C2M handles or protects your Information, please bring it to C2M’s attention (see “How to Contact C2M” below). In compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Principles, C2M commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact C2M (see “How to Contact C2M” below).

 

C2M has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

 

C2M is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. There is the possibility, under certain circumstances, for EU and Swiss individuals to invoke additional binding arbitration.

 

C2M retains sole and absolute discretion in resolving all questions relating to the administration, interpretation and application of this Policy. This authority includes construing the terms of this Policy, including any disputed or doubtful terms.

 

No Rights of Third Parties

 

This Policy does not create rights enforceable by third parties.

 

How to Contact C2M

 

If you have any questions about this Policy, please;

 

Call:     (877) 787-7017

Email:  privacy@capital2market.com

Write: Legal Department – Privacy 

            1200 E. Byrd St., Suite 5200

            Richmond, VA 23219