Effective Date: October 1st, 2020
At EquityZen Inc. (the “Company”), your privacy is very important to us. We also value transparency and want to be clear about how we collect, use and share information about you.
This policy is here to help you understand:
This Privacy Policy applies to you when you access or use any domains or subdomains of EquityZen’s website at https://equityzen.com/ (the “Site”), download and/or use EquityZen’s application (the “Application”), or when you access, use, or download any other products, services, features, content, widgets, materials or other tools offered by the Company or its subsidiaries and affiliates, including EquityZen Securities LLC and EquityZen Advisors LLC (collectively the “Services”). “EquityZen”, “we”, “us”, and “our” refer to the Company together with any of our subsidiaries and corporate affiliates. For more information about our Terms of Use, please click here.
We collect the categories of personal information listed below:
We collect information from you when you input it or otherwise provide it directly to us.
Account Information: We collect information about you when you create an account or sign up for Services. For example, you provide your name, email address, password, and phone number when you create an account. You also select whether you are a signing up as an investor or a shareholder. Depending on the Services you select, you provide your address, date of birth, and taxpayer ID, such as a social security number or other government issued ID number. We collect this information to verify your identity and to help the government fight the funding of terrorism and money-laundering activities, as required by US law. If you register or use the Services through third-party sites or applications, such as Google, we may gather information from them.
Bank, Brokerage and Other Payment Information: To transact with us, you provide your banking information, including bank account and routing number, to permit you to send funds to us or receive funds from us by wire, or in the United States, by ACH transfer. You may also provide us other payment information when you elect to send funds to us using alternative payment methods. If you invest with us in an investment where a private company experiences an IPO (or a direct listing or other exit event), you may provide us your brokerage information to enable us to send you shares following the exit event.
Buyer Information: To make investments with us, when you create an account or sign up for Services, you provide us information concerning whether you are investing on your own behalf or that of an institution, your status as an accredited investor, your investment objectives, risk tolerance, investment time-horizon, investment experience, and information concerning your income and/or net worth. You also provide certain commercial information and information about your investment preferences, which become a part of your investor profile, and may include how much you anticipate investing in certain asset classes, your target investment size per investment, the asset classes you have invested in, and sectors of interest.
For investments related to some issuers, you may also provide us employment information or representations that you are not affiliated with, or employed by, a competitor of that issuer. If you express interest in investing in a particular investment opportunity, you provide us information about your interest and preferences which may include the investment amount and other information regarding your interest in making an investment.
Seller Information: To sell private company equity with us, you provide us information and documents concerning your ownership of shares or options. For example, you provide information about the company in which you own the shares, ownership type, and the number of shares you want to sell. If you are a seller, you also provide us information and documents reflecting your vesting and other attributes applicable to your shares or options. You may also be asked to provide your spouse’s name and email address if you are married. You also provide information about your preferences, such as, for example, the price at which you desire to sell your shares.
Support Information and Other Communications: The Services include customer support, where you may choose to submit information or questions concerning a problem you are experiencing with a Service or questions you have about a Service. You may also provide, or be asked to provide, screenshots, documentation or information to help us address your problem or respond to your question.
You may also provide us with feedback and survey responses when using the Service, as well as other information you voluntarily provide to us when communicating with us, such as via email, any chat bots available on the Site and/or the Application, or via other actions you perform when using the Services. You may also provide us with your marketing and email preferences in your account settings.
Trust Information: If you purchase or sell securities held in the name of the trust, you provide us with additional information and documents concerning the identity and contact information of individuals related to the trust.
Trusted Contact Person: You are permitted, but not required, to provide the name and contact information of a Trusted Contact Person who can be contacted about your account. For more information about FINRA’s Trusted Contact Person program, please click here.
Verification Information and Documents: If required to help us verify your identity, you may provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering, US Treasury department rules or regulations or other legal requirements. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship status.
Voluntary Information: If you authorize your accountant, financial advisor, lawyer or relative to receive information about our Services on your behalf, or to take actions on the Site on your behalf, you provide us the name and contact information for the person you authorize. If you are a selling shareholder and have a preferred representative at your current or former company with whom you’d like us to communicate, you provide us the name and contact information of that preferred representative.
Transaction Information: We collect information in connection with the transactions you become a party to through our Services as either a seller or a buyer (“Transaction Data”). Transaction Data includes, without limitation, the terms on which you purchase or sell securities and information relating to price, size, volume, class of securities, bids, offers, transfer restrictions, and any derivative data related thereto.
We collect the following categories of information about you when you use our services, including when visiting the Site or the Application, and taking certain actions within the Services.
Information About Your Use of the Services: We collect certain information about you when you visit the Site and interact with any of our Services. We collect information about when you use Services, the pages within the Site and/or the Application you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Site or Application, we retain information about your referral.
Device and Connection Information: We collect information about your computer, phone, tablet or other device you use to access the Services. This device information may include your operating system, browser type, IP address, URLs of referring pages, App name and version, and device identifiers.
Cookies, Web Beacons, Pixel Tags and Other Similar Technologies: EquityZen and its third-party service providers, such as our analytics and advertising partners, collect certain information using cookies, web beacons, pixel tags and other similar technologies to provide functionality, enable and support security features, recognize you across different devices, improve our offerings, understand how you use and interact with our Services, improve performance of Services, and otherwise manage and enhance Services. “Cookies” are simple text files stored on your device for use by a browser. “Web Beacons” or “pixel tags” are small images, often transparent, on a website or email that are used to observe if you have accessed content. Using cookies, web beacons or pixel tags, or other tracking technologies are standard practices on internet web sites.
Some web browsers transmit “do-not-track” signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers.
We use session cookies to make it easier for you to use our Services and to identify you while you are on the Site or Application. We also use persistent cookies to make it easier for you to navigate the Site and track whether you are logged into the Site. A persistent cookie remains on your device’s hard drive for an extended time. You can remove persistent cookies by following the directions provided in your internet browser’s “help” file. If you reject persistent cookies, you will still be able to view the Site, but your ability to use some areas of the Site, such as automatically-generated recommendations, will be limited.
We receive information about you from third-party services and business partners.
Third-Party Identity Verification Service Provider: We receive information about you from a third-party identity verification service provider to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services.
Marketing and Advertising Services and Partners: We receive information about you and your activities on and off the Services from third-party service providers, such as Google, Mixpanel, HotJar, LinkedIn and other advertising, social media and market research partners who provide us with information about you, and/or your engagement with and interest in our Services.
Business Partners: We may receive information about you from our third-party partners, under referral programs, partnership agreements and/or under joint marketing arrangements.
We use the information we collect based on the Services you choose to receive. The specific purposes are described below.
To Provide the Services and Personalize Your Experience: We use information about you to provide the Services to you, including to process transactions for you, authenticate you when you log in, verify your identity, and, if you are seeking to invest, determine your eligibility for investments. We also use information you provide to validate that information, comply with legal requirements, provide customer support and communicate with you, and operate and maintain the Services. For example, we use the banking information you provide to send you funds when they are due to you, from selling securities on the Site or when proceeds are due to you from investments made through the Site.
We also use information about you to personalize and improve your experience while using the Services and to determine effectiveness of the Services. We also use information about you and your activities to provide an integrated experience, such as allowing you to access the Services from multiple devices.
To Communicate With You About the Services: We use your contact information to send communications to you (typically via email) about your transactions, including confirming the terms on which you purchase or sell securities, updating you on the status of transactions and related deadlines, responding to your questions or comments, and providing information received from the issuer or, when applicable, other parties to your transactions. If you are eligible to invest through the Site, we send you notifications about potential investment opportunities available through the Site. We also provide tailored communications to you based on actions you take on the Site. For example, if you start the investment process on the Site, we will use your contact information to remind you to come back and complete the investment process. We also send you communications about the Services as part of onboarding to help you understand and use the Services.
If you download and/or use the Application, and if you are a registered user of the Application, we may send push notifications to your device as a way to deliver information, offers, alerts, updates, reminders, news, and other relevant notifications pertaining to Services, including messages, sounds, and hyperlinks to pages within the Application, or hyperlinks to pages on the Site. Push notifications may be controlled from within the Application’s settings and at the device’s operating system “OS” level at any time. For additional information about push notifications, please see our Terms of Use.
To Operate the Services: We share information about you as needed with our own service providers, including financial institutions, fund administrators, accountants, auditors, lawyers, payment providers, information technology staff, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Site and the Services.
For Research and Development: We strive to make our Services better, smarter, faster, more secure and easier to use. We collect information about how people use the Services and feedback provided directly to us to identify trends and problems, usage and activity patterns, and areas for integrating and improving our Services. We may also test and analyze certain new features with some users before rolling out the features to all users.
To Market, Promote and Drive Engagement With the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of interest to you, including by email and by displaying our content on other websites and applications, such as on platforms including Google or Facebook. These communications are intended to increase engagement and what you get out of the Services, including information about new features, new content, and events we think may be of interest to you. We also communicate with you about new products and services and promotions.
We do not – and do not plan to – rent or sell personally identifiable information about you to other people or to non-affiliated companies.
For Safety and Security: We use information about you and your Service use to verify your identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies. We also use your information to debug, identify and fix errors that impair how our Services function.
As Required by Law or Regulations: We retain information about you that is required by US law or regulation, including those applicable to the sale of securities or operating an investment advisor or broker-dealer. In general, we are required to retain these records for at least three years, and up to six years (and in some circumstances, longer). We may keep some information longer to meet our needs and those of our customers, even after you close or deactivate your account, including for backup, archives, contract enforcement, dispute resolution. We may access and disclose information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.
For a Merger, Sale or Other Asset Transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of EquityZen’s assets, or other corporate transaction affecting EquityZen, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract.
Legal Bases for Processing (for EEA users): If you are an individual residing in the European Economic Area (“EEA”), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the General Data Protection Regulation (“GDPR”). The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services.
To do so, please email us at support@equityzen.com.
We manage a private company equity marketplace, and we want it to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you with third parties in the ways discussed below, including in connection with possible business transfers.
With Affiliates of EquityZen: If you are a party to a prospective or actual transaction, we share information about you with our affiliates, including our broker-dealer, EquityZen Securities LLC, and our investment advisor, EquityZen Advisors LLC, to provide you Services relating to that transaction.
With Parties to a Transaction, Companies and Service Providers: If you are a party to a prospective or actual transaction, we will give the other party (or other parties) to the transaction the information they need to evaluate and enter that transaction. If you enter into a transaction with a third-party company, such as by becoming a shareholder, that company will receive information about you subject to its own privacy policy, and may be required to disclose that information to its own board members, officers, investors or shareholders.
We also provide your information where necessary for a transaction or to comply with legal requirements. For example, we may provide certain aspects of your information to financial institutions, payment processors, fund administrators, accountants, auditors, lawyers, payment providers, third-party hosting service, email and technology service providers, information technology staff, advisors, affiliates, marketing and analytics partners, or third-party verification services.
As part of providing their services to us, our marketing and advertising service providers mentioned above may use cookies and other technologies to collect data on our users’ behavior and their devices. This may include, for example, a device's IP address, device type (unique device identifiers), browser information, and geographic location (region and/or country only).
We do not and will not sell your personally identifiable information. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data.
We may share aggregated, deidentified and/or anonymized information that does not specifically identify you or any individual user of our Services for any purpose with any third-parties, including but not limited with advertisers, national industry organizations, and prospective affiliates, or as permitted or required by law, or to protect our rights.
With Regulators: We may share information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.
We may also share information about you to protect the security and integrity of our Services, to protect EquityZen’s interests, or those of other persons or the public.
With Business Partners: We may share information about you with our third-party partners under referral programs, partnership agreements or under joint marketing arrangements.
With Third-Party Sites: The Site may contain links to third party web sites and may redirect you to third party web sites ("Third Party Sites"). These sites include, among others, service providers who have a relationship with the Company. Third Party Sites are not under our control, and we are not responsible for any Third Party Sites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to Third Party Sites does not imply an endorsement thereof by the Company, or of the provider of such content or services, or of any third party web site. The Company reserves the right to terminate any link or linking program at any time. Please be aware that when you enter a third party web site, any information you provide, including financial information, is subject to the terms of use and privacy policy of that site.
With Your Consent: We share information about you where you have given us consent to do so for a specific purpose. For example, we may disclose information to your financial advisor, accountant attorney or spouse, or other individual or company you authorize to receive information about you.
Business Transfers: We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information.
We take steps to ensure that your information is treated securely and in accordance with this policy. While we use industry-accepted security principles, practices, and tools, the internet is not 100% secure and we cannot ensure or guarantee the security of data, during transmission through the Internet or while stored on our systems or otherwise in our care. We do not accept liability for unintentional disclosure.
By using the Service or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing.
We use a data hosting service provider in the United States to host the information we collect, and we use technical measures to secure your data. We use industry-accepted practices, including 256-bit encryption, to protect customer-related information and also use field-level encryption on highly sensitive data. Information is encrypted at rest and in transit from client to web to web server, including proxies, and to the database.
We request third party service providers to agree to keep your information confidential by entering into agreements that limit their use of the information they receive about you for purposes of performing the services for which they are being retained.
If you are outside the United States, by using the Services or visiting the Site, you will transfer data to the United States and are permitting your information to be used in accordance with this Privacy Policy.
You have choices and rights available to you when it comes to your information. They are summarized below.
Your Rights as a California Resident: Residents of California have the right to request from us, one time per year, certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
To exercise your rights, please use one of the submission methods mentioned below under “Submitting Requests Pertaining to Your Information".
Your Rights as a Vermont Resident: We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, please contact us for assistance at support@equityzen.com, though we will no longer be able to provide you Services or access to the Site.
If You are a European Economic Area Resident: If you are an EEA data subject, you may review, correct or update the personal data you provide at any time.
If you would like to exercise your GDPR rights, please use one of the submission methods mentioned below under “Submitting Requests Pertaining to Your Information”.
In the event of a data breach, we will endeavor to notify you within 72 hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the General Data Protection Regulation. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.
Access to Your Data and Documents: You may review, correct or update the personal data you provide at any time. You may access your documents relating to your transactions at any time by logging in into your account and navigating to the “My Documents” and the “My Transactions” section of the Site or Application. If you need assistance, please contact us at support@equityzen.com.
Unsubscribe Options: If you chose to use the Services, you will receive periodic emails or other electronic communications from us which, based on the information you provide, may be of interest. If you no longer wish to receive our communications, you may unsubscribe by following the instructions included in each communication.
Children’s Privacy: The Site and our Services are not directed to any person under the age of 18. If you become aware that your child has provided us with personal data without your consent, please contact us at support@equityzen.com. We do not knowingly collect or solicit information from, market to, or accept services from children.
Lost or Stolen Information: You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen or used without permission.
Changes to this Policy: Each time you visit the Site or use the Services, the current version of the Policy will apply. When you use the Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We may require you to affirmatively assent to a revised version of this Policy as a condition of continuing to use the Site or our Services.
Submitting Requests Pertaining to Your Information: If you would like to make a request regarding your information, you may do so, free of charge, by clicking here. You will be redirected to fill out a form with certain information about your request. *If you have a registered account on the Site or the Application, please make sure to login to your account before submitting your request.* This will help us verify your identity.
Please note that for all requests, we will need to verify your identity to confirm that you are the individual about whom we have collected personal information.
You may also submit your request by calling our toll-free number at (877) 490-6121.
Contact Us: Your information is controlled by EquityZen Inc. If you have any questions or concerns about how your information is handled you may contact us at:
EquityZen Inc. 30 Broad Street, Suite 1200 New York, New York 10004 (877) 490-6121 support@equityzen.com
At EquityZen Inc. (the “Company”), your privacy is very important to us. We also value transparency and want to be clear about how we collect, use and share information about you.
This policy is here to help you understand:
This Privacy Policy applies to you when you visit https://equityzen.com/ (the “Site”) or when you use the products services of the Company and its subsidiaries and affiliates (the “Services”). EquityZen, we and us refer to the Company together and any of our subsidiaries and corporate affiliates. For more information about our Terms of Use, please click here.
This Privacy Policy goes into effect starting on December 13th, 2018.
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us.
We collect information from you when you input it or otherwise provide it directly to us.
Account Information: We collect information about you when you create an account or sign up for Services. For example, you provide your name, email address and phone number when you create an account. Depending on the Services you elect, you also provide your address, date of birth and taxpayer ID, such as a social security number or other government issued ID number. We collect this information to verify your identity and to help the government fight the funding of terrorism and money-laundering activities, as required by US law. If you register or use the Services through third-party sites or applications, such as Google, we may gather information from them.
Bank, Brokerage and Other Payment Information: To transact with us, you provide your banking information, including bank account and routing number, to permit you to send funds to us or receive funds from us by wire, or in the United States, by ACH transfer. You may also elect to provide us alternative payment information for some payments, such as credit card details or payment services such as Venmo. If you invest with us in an investment where a private company experiences an IPO (or a direct listing or other exit event), you may provide us your brokerage information to enable us to send you shares following the exit event. If you elect to sign up for an EquityZen Investor account, you provide additional information required by our banking-services provider, SynapseFI, and Evolve Bank & Trust, member FDIC, including your gender and occupation.
Buyer Information: To make investments with us, you provide us information concerning your investment objectives, risk tolerance, time-horizon, investment objectives, as well as information concerning your income and/or net worth. For investments related to some issuers, you may also provide us information concerning your employment or provide representations that you are not affiliated with, or employed by, a competitor of that issuer. If you express interest in investing in a particular investment opportunity, you provide us information about your interest which may include the investment amount and other information regarding your interest in making an investment.
Seller Information: To sell private company equity with us, you provide us information and documents concerning your ownership of shares or options. If you are a seller, you also provide us information and documents reflecting your vesting and other attributes applicable to your shares or options. You may also be asked to provide your spouse’s name and email address if you are married.
Support Information: The Services include customer support, where you may choose to submit information or questions concerning a problem you are experiencing with a Service or questions you have about a Service. You may also provide, or be asked to provide, screenshots, documentation or information to help us address your problem or respond to your question.
Trust Information: If you purchase or sell securities held in the name of the trust, you provide us with additional information and documents concerning the identity and contact information of individuals related to the trust.
Trusted Contact Person: You are permitted, but not required, to provide the name and contact information of a Trusted Contact Person who can be contacted about your account. For more information about FINRA’s Trusted Contact Person program, please click here.
Verification Information and Documents: If required to help us verify your identity, you may provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering, US Treasury department rules or regulations or other legal requirements.
Voluntary Information: If you authorize your accountant, financial advisor, lawyer or relative to receive information about our Services on your behalf, or to take actions on the Site on your behalf, you provide us the name and contact information for the person you authorize. If you are a selling shareholder and have a preferred representative at your current or former company with whom you’d like us to communicate, you provide us the name and contact information of that preferred representative.
We collect information about you when you use our services, including visiting the Site and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit the Site and interact with any of our Services. We collect information about the pages within the Site you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Site, we retain information about your referral.
Device and Connection Information: We collect information about your computer, phone, tablet or other device you use to access the Services. This device information may include your operating system, browser type, IP address, URLs of referring pages, and device identifiers.
Cookies, Web Beacons, Pixel Tags and Other Tracking Technologies: EquityZen and its third-party providers, such as our analytics and advertising partners, use cookies, web beacons, pixel tags other tracking technologies to provide functionality and to recognize you across different devices. “Cookies” are simple text files stored on your device for use by a browser. “Web Beacons” or “pixel tags” are small images, often transparent, on a website or email that are used to observe if you have accessed content. Using cookies, web beacons or pixel tags, or other tracking technologies are standard practices on internet web sites. We use persistent cookies to make it easier for you to navigate the Site and track whether you are logged into the Site. A persistent cookie remains on your device’s hard drive for an extended of time. You can remove persistent cookies by following the directions provided in your internet browser’s “help” file. If you reject persistent cookies, you will still be able to view the Site, but your ability to use some areas of the Site, such as automatically-generated recommendations, will be limited.
We receive information about you from third-party services and business partners.
Third-Party Financial Services Provider: We receive information about you and your banking information, including account number, routing number and account balance through our third-party financial services provider Synapse (see our Terms) to help us facilitate transfers of funds to us for transactions, or into and out of your Investor Account.
Third-Party Identity Verification Partner: We receive information about you from a third-party identity verification partner to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services.
Marketing and Advertising Services and Partners: We receive information about you and your activities on and off the Services from third-party partners, such as Google, Mixpanel, LinkedIn and other advertising, social media and market research partners who provide us with information about your engagement with, and interest in our Services.
We use the information we collect based on the Services you choose to receive. The specific purposes are described below.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions for you, authenticate you when you log in, verify your identity, and, if you are seeking to invest, determine your eligibility for investments. We also use information you provide to validate that information, comply with legal requirements, provide customer support and communicate with you, and operate and maintain the Services. For example, we use the banking information you provide to send you funds when they are due to you, from selling securities on the Site or when proceeds are due to you from investments made through the Site. We also use information about you to personalize your experiences using the Services. We use information about you and your activities to provide an integrated experience, such as allowing you to access the Services from multiple devices.
To communicate with you about the Services: We use your contact information to send communications to you (typically via email) about your transactions, including confirming the terms on which you purchase or sell securities, updating you on the status of transactions and related deadlines, responding to your questions or comments, and providing information received from the issuer or, when applicable, other parties to your transactions. If you are eligible to invest through the Site, we send you email notifications about potential investment opportunities available through the Site. We also provide tailored communications to you based actions you take on the Site. For example, if you start the investment process on the Site, we will use your contact information to remind you to come back and complete the investment process. We also send you communications about the Services as part of onboarding to help you understand and use the Services.
To operate the Services: We share information about you as needed with our own service providers, including financial institutions, fund administrators, accountants, auditors, lawyers, payment providers, information technology staff, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Site and the Services.
For research and development: We strive to make our Services better, smarter, faster, more secure and easier to use. We collect information about how people use the Services and feedback provided directly to us to identify trends and problems, usage and activity patterns, and areas for integrating and improving our Services. We may also test and analyze certain new features with some users before rolling out the features to all users.
To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of interest to you, including by email and by displaying our content on other websites and applications, such as on platforms including Google or Facebook. These communications are intended to increase engagement and what you get out of the Services, including information about new features, new content, and events we think may be of interest to you. We also communicate with you about new products and services and promotions. We do not--and do not plan to--rent, sell, or share information about you with other people or with non-affiliated companies.
For safety and security: We use information about you and your Service use to verify your identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies.
As required by law or regulations: We retain information about you that is required by US law or regulation, including those applicable to the sale of securities or operating an investment advisor or broker-dealer. In general, we are required to retain these records for at least three years, and up to six years (and in some circumstances, longer). We may keep some information longer to meet our needs and those of our customers, even after you close or deactivate your account, including for backup, archives, contract enforcement, dispute resolution. We may access and disclose information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.
For a merger, sale or other asset transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of EquityZen’s assets, or other corporate transaction affecting EquityZen, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law aor by contract.
Legal bases for processing (for EEA users): If you are an individual residing in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the General Data Protection Regulation. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services. To do so, please email us at support@equityzen.com.
We manage a private company equity marketplace, and we want it to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.
With affiliates of EquityZen: If you are a party to a prospective or actual transaction, we share information about you with our affiliates, including our broker-dealer, EquityZen Securities LLC, and our investment advisor, EquityZen Advisors LLC, to provide you Services relating to that transaction.
With companies and service providers: If you are a party to a prospective or actual transaction, we will give the other party (or other parties) to the transaction the information they need to evaluate and enter that transaction. If you enter into a transaction with a third-party company, such as by becoming a shareholder, that company will receive information about you subject to its own privacy policy, and may be required to disclose that information to its own board members, officers, investors or shareholders. We also provide your information where necessary for a transaction or to comply with legal requirements. For example, we may provide certain aspects of your information to our financial institutions, payment processors, fund administrators, accountants, auditors, lawyers, payment providers, third-party hosting service, email and technology providers, information technology staff, advisors, affiliates, marketing and analytics partners, or third-party verification services. If you elect to open an EquityZen Investor Account, we share information with our third-party banking services provider, SynapseFI, and with Evolve Bank & Trust, member FDIC. Once shared with SynapseFI and Evolve Bank & Trust, their use of your information is governed by the Synapse Privacy Policy and the Evolve Bank & Trust Privacy Policy. We may share information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas. We may share aggregate (non-personally identifiable) information with third-parties such as advertisers, national industry organizations, and prospective affiliates, or as permitted or required by law, or to protect our rights. We may also share information about you to protect the security and integrity of our Services, to protect EquityZen’s interests, or those of other persons or the public, and under referral programs with our partners or under joint marketing arrangements.
With Third-Party Sites: The Site may contain links to third party web sites and may redirect you to third party web sites ("Third Party Sites"). These sites include, among others, service providers who have a relationship with the Company. Third Party Sites are not under our control, and we are not responsible for any Third Party Sites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to Third Party Sites does not imply an endorsement thereof by the Company, or of the provider of such content or services, or of any third party web site. The Company reserves the right to terminate any link or linking program at any time. Please be aware that when you enter a third party web site, any information you provide, including financial information, is subject to the terms of use and privacy policy of that site.
With your consent: We share information about you where you have given us consent to do so for a specific purpose. For example, we may disclose information to your financial advisor, accountant attorney or spouse, or other individual you authorize to receive information about your account.
Business Transfers: We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information.
We take steps to ensure that your information is treated securely and in accordance with this policy. While we use industry-accepted security principles, practices, and tools, the internet is not 100% secure and we cannot ensure or guarantee the security of data, during transmission through the Internet or while stored on our systems or otherwise in our care. We do not accept liability for unintentional disclosure.
By using the Service or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing.
We use a data hosting service provider in the United States to host the information we collect, and we use technical measures to secure your data. We use industry-accepted practices, including 256-bit encryption, to protect customer-related information and also use field-level encryption on highly sensitive data. Information is encrypted at rest and in transit from client to web to web server, including proxies, and to the database. We require third parties who perform services for EquityZen to agree to keep your information confidential. If you are outside the United States, by using the Services or visiting the Site, you will transfer data to the United States and are permitting your information to be used in accordance with this Privacy Policy.
You have choices and rights available to you when it comes to your information. They are summarized below.
Your rights as a California resident: Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at support@equityzen.com specifying the email address associated with your account and your full legal name.
Your rights as a Vermont resident: We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, please contact us for assistance at support@equityzen.com, though we will no longer be able to provide you Services or access to the Site.
If you are a European Economic Area resident: If you are an EEA data subject, you may review, correct or update the personal data you provide at any time. If you would like to do so, please contact us for assistance at support@equityzen.com. In the event of a data breach, we will endeavor to notify you within 72 hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the General Data Protection Regulation. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.
Access to your data and documents: You may review, correct or update the personal data you provide at any time. You may access your documents relating to your transactions at any time by logging in under the “My Documents” and the “My Transactions” section of the Site. If you need assistance, please contact us at support@equityzen.com.
Unsubscribe options: If you chose to use the Services, you will receive periodic emails or other electronic communications from us which, based on the information you provide, may be of interest. If you no longer wish to receive our communications, you may unsubscribe by following the instructions included in each communication.
Children’s Privacy: The Site and our Services are not directed to any person under the age of 18. If you become aware that your child has provided us with personal data without your consent, please contact us at support@equityzen.com. We do not knowingly collect or solicit information from, market to, or accept services from children.
Lost or Stolen Information: You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen or used without permission.
Banking Services for EquityZen Investment Account Users: Bank services are provided through our banking software provider, SynapseFi. To report a complaint relating to the banking services, email help@synapsefi.com.
Changes to this Policy: Each time you visit the Site or use the Services, the current version of the Policy will apply. When you use the Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We may require you to affirmatively assent to a revised version of this Policy as a condition of continuing to use the Site or our Services.
Contact us: Your information is controlled by EquityZen Inc. If you have any questions or concerns about how your information is handled you may contact us at:
EquityZen Inc. 30 Broad Street, Suite 1200 New York, New York 10004 (877) 490-6121 support@equityzen.com
At EquityZen Inc. (the “Company”), your privacy is very important to us. We also value transparency and want to be clear about how we collect, use and share information about you.
This policy is here to help you understand:
This Privacy Policy applies to you when you visit https://equityzen.com/ (the “Site”) or when you use the products services of the Company and its subsidiaries and affiliates (the “Services”). EquityZen, we and us refer to the Company together and any of our subsidiaries and corporate affiliates. For more information about our Terms of Use, please click here.
This Privacy Policy goes into effect starting on May 25, 2018.
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us.
We collect information from you when you input it or otherwise provide it directly to us.
Account Information: We collect information about you when you create an account or sign up for Services. For example, you provide your name, email address and phone number when you create an account. Depending on the Services you elect, you also provide your address, date of birth and taxpayer ID, such as a social security number or other government issued ID number. We collect this information to verify your identity and to help the government fight the funding of terrorism and money-laundering activities, as required by US law. If you register or use the Services through third-party sites or applications, such as Google, we may gather information from them.
Bank, Brokerage and Other Payment Information: To transact with us, you provide your banking information, including bank account and routing number, to permit you to send funds to us or receive funds from us by wire, or in the United States, by ACH transfer. You may also elect to provide us alternative payment information for some payments, such as credit card details or payment services such as Venmo. If you invest with us in an investment where a private company experiences an IPO (or a direct listing or other exit event), you may provide us your brokerage information to enable us to send you shares following the exit event.
Buyer Information: To make investments with us, you provide us information concerning your investment objectives, risk tolerance, time-horizon, investment objectives, as well as information concerning your income and/or net worth. For investments related to some issuers, you may also provide us information concerning your employment or provide representations that you are not affiliated with, or employed by, a competitor of that issuer. If you express interest in investing in a particular investment opportunity, you provide us information about your interest which may include the investment amount and other information regarding your interest in making an investment.
Seller Information: To sell private company equity with us, you provide us information and documents concerning your ownership of shares or options. If you are a seller, you also provide us information and documents reflecting your vesting and other attributes applicable to your shares or options. You may also be asked to provide your spouse’s name and email address if you are married.
Support Information: The Services include customer support, where you may choose to submit information or questions concerning a problem you are experiencing with a Service or questions you have about a Service. You may also provide, or be asked to provide, screenshots, documentation or information to help us address your problem or respond to your question.
Trust Information: If you purchase or sell securities held in the name of the trust, you provide us with additional information and documents concerning the identity and contact information of individuals related to the trust.
Trusted Contact Person: You are permitted, but not required, to provide the name and contact information of a Trusted Contact Person who can be contacted about your account. For more information about FINRA’s Trusted Contact Person program, please click here
Verification Information and Documents: If required to help us verify your identity, you may provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering, US Treasury department rules or regulations or other legal requirements.
Voluntary Information: If you authorize your accountant, financial advisor, lawyer or relative to receive information about our Services on your behalf, or to take actions on the Site on your behalf, you provide us the name and contact information for the person you authorize. If you are a selling shareholder and have a preferred representative at your current or former company with whom you’d like us to communicate, you provide us the name and contact information of that preferred representative.
We collect information about you when you use our services, including visiting the Site and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit the Site and interact with any of our Services. We collect information about the pages within the Site you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Site, we retain information about your referral.
Device and Connection Information: We collect information about your computer, phone, tablet or other device you use to access the Services. This device information may include your operating system, browser type, IP address, URLs of referring pages, and device identifiers.
Cookies, Web Beacons, Pixel Tags and Other Tracking Technologies: EquityZen and its third-party providers, such as our analytics and advertising partners, use cookies, web beacons, pixel tags other tracking technologies to provide functionality and to recognize you across different devices. “Cookies” are simple text files stored on your device for use by a browser. “Web Beacons” or “pixel tags” are small images, often transparent, on a website or email that are used to observe if you have accessed content. Using cookies, web beacons or pixel tags, or other tracking technologies are standard practices on internet web sites. We use persistent cookies to make it easier for you to navigate the Site and track whether you are logged into the Site. A persistent cookie remains on your device’s hard drive for an extended of time. You can remove persistent cookies by following the directions provided in your internet browser’s “help” file. If you reject persistent cookies, you will still be able to view the Site, but your ability to use some areas of the Site, such as automatically-generated recommendations, will be limited.
We receive information about you from third-party services and business partners.
Third-Party Identity Verification Partner: We receive information about you from a third-party identity verification partner to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services.
Marketing and Advertising Services and Partners: We receive information about you and your activities on and off the Services from third-party partners, such as Google, Mixpanel, LinkedIn and other advertising, social media and market research partners who provide us with information about your engagement with, and interest in our Services.
We use the information we collect based on the Services you choose to receive. The specific purposes are described below.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions for you, authenticate you when you log in, verify your identity, and, if you are seeking to invest, determine your eligibility for investments. We also use information you provide to validate that information, comply with legal requirements, provide customer support and communicate with you, and operate and maintain the Services. For example, we use the banking information you provide to send you funds when they are due to you, from selling securities on the Site or when proceeds are due to you from investments made through the Site. We also use information about you to personalize your experiences using the Services. We use information about you and your activities to provide an integrated experience, such as allowing you to access the Services from multiple devices.
To communicate with you about the Services: We use your contact information to send communications to you (typically via email) about your transactions, including confirming the terms on which you purchase or sell securities, updating you on the status of transactions and related deadlines, responding to your questions or comments, and providing information received from the issuer or, when applicable, other parties to your transactions. If you are eligible to invest through the Site, we send you email notifications about potential investment opportunities available through the Site. We also provide tailored communications to you based actions you take on the Site. For example, if you start the investment process on the Site, we will use your contact information to remind you to come back and complete the investment process. We also send you communications about the Services as part of onboarding to help you understand and use the Services.
To operate the Services: We share information about you as needed with our own service providers, including financial institutions, fund administrators, accountants, auditors, lawyers, payment providers, information technology staff, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Site and the Services.
For research and development: We strive to make our Services better, smarter, faster, more secure and easier to use. We collect information about how people use the Services and feedback provided directly to us to identify trends and problems, usage and activity patterns, and areas for integrating and improving our Services. We may also test and analyze certain new features with some users before rolling out the features to all users.
To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of interest to you, including by email and by displaying our content on other websites and applications, such as on platforms including Google or Facebook. These communications are intended to increase engagement and what you get out of the Services, including information about new features, new content, and events we think may be of interest to you. We also communicate with you about new products and services and promotions. We do not--and do not plan to--rent, sell, or share information about you with other people or with non-affiliated companies.
For safety and security: We use information about you and your Service use to verify your identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies.
As required by law or regulations: We retain information about you that is required by US law or regulation, including those applicable to the sale of securities or operating an investment advisor or broker-dealer. In general, we are required to retain these records for at least three years, and up to six years (and in some circumstances, longer). We may keep some information longer to meet our needs and those of our customers, even after you close or deactivate your account, including for backup, archives, contract enforcement, dispute resolution. We may access and disclose information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.
For a merger, sale or other asset transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of EquityZen’s assets, or other corporate transaction affecting EquityZen, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law aor by contract.
Legal bases for processing (for EEA users): If you are an individual residing in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the General Data Protection Regulation. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services. To do so, please email us at support@equityzen.com.
We manage a private company equity marketplace, and we want it to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.
With affiliates of EquityZen: If you are a party to a prospective or actual transaction, we share information about you with our affiliates, including our broker-dealer, EquityZen Securities LLC, and our investment advisor, EquityZen Advisors LLC, to provide you Services relating to that transaction.
With companies and service providers: If you are a party to a prospective or actual transaction, we will give the other party (or other parties) to the transaction the information they need to evaluate and enter that transaction. If you enter into a transaction with a third-party company, such as by becoming a shareholder, that company will receive information about you subject to its own privacy policy, and may be required to disclose that information to its own board members, officers, investors or shareholders. We also provide your information where necessary for a transaction or to comply with legal requirements. For example, we may provide certain aspects of your information to our financial institutions, payment processors, fund administrators, accountants, auditors, lawyers, payment providers, third-party hosting service, email and technology providers, information technology staff, advisors, affiliates, marketing and analytics partners, or third-party verification services. We may share information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas. We may share aggregate (non-personally identifiable) information with third-parties such as advertisers, national industry organizations, and prospective affiliates, or as permitted or required by law, or to protect our rights. We may also share information about you to protect the security and integrity of our Services, to protect EquityZen’s interests, or those of other persons or the public, and under referral programs with our partners or under joint marketing arrangements.
With Third-Party Sites: The Site may contain links to third party web sites and may redirect you to third party web sites ("Third Party Sites"). These sites include, among others, service providers who have a relationship with the Company. Third Party Sites are not under our control, and we are not responsible for any Third Party Sites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates.. The inclusion or access to Third Party Sites does not imply an endorsement thereof by the Company, or of the provider of such content or services, or of any third party web site. The Company reserves the right to terminate any link or linking program at any time. Please be aware that when you enter a third party web site, any information you provide, including financial information, is subject to the terms of use and privacy policy of that site.
With your consent: We share information about you where you have given us consent to do so for a specific purpose. For example, we may disclose information to your financial advisor, accountant attorney or spouse, or other individual you authorize to receive information about your account.
Business Transfers: We may share or transfer information we collect under this privacy policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information.
We take steps to ensure that your information is treated securely and in accordance with this policy. While we use industry-accepted security principles, practices, and tools, the internet is not 100% secure and we cannot ensure or guarantee the security of data, during transmission through the Internet or while stored on our systems or otherwise in our care. We do not accept liability for unintentional disclosure.
By using the Service or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing.
We use a data hosting service provider in the United States to host the information we collect, and we use technical measures to secure your data. We use industry-accepted practices, including 256-bit encryption, to protect customer-related information and also use field-level encryption on highly sensitive data. Information is encrypted at rest and in transit from client to web to web server, including proxies, and to the database. We require third parties who perform services for EquityZen to agree to keep your information confidential. If you are outside the United States, by using the Services or visiting the Site, you will transfer data to the United States and are permitting your information to be used in accordance with this Privacy Policy.
You have choices and rights available to you when it comes to your information. They are summarized below.
Your rights as a California resident: Residents of California have the right to request from us certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at support@equityzen.com specifying the email address associated with your account and your full legal name.
Your rights as a Vermont resident: We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, please contact us for assistance at support@equityzen.com, though we will no longer be able to provide you Services or access to the Site.
If you are a European Economic Area resident: If you are an EEA data subject, you may review, correct or update the personal data you provide at any time. If you would like to do so, please contact us for assistance at support@equityzen.com . In the event of a data breach, we will endeavor to notify you within 72 hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the General Data Protection Regulation. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.
Access to your data and documents: You may review, correct or update the personal data you provide at any time. You may access your documents relating to your transactions at any time by logging in under the “My Documents” and the “My Transactions” section of the Site. If you need assistance, please contact us at support@equityzen.com.
Unsubscribe options: If you chose to use the Services, you will receive periodic emails or other electronic communications from us which, based on the information you provide, may be of interest. If you no longer wish to receive our communications, you may unsubscribe by following the instructions included in each communication.
Children’s Privacy: The Site and our Services are not directed to any person under the age of 18. If you become aware that your child has provided us with personal data without your consent, please contact us at support@equityzen.com. We do not knowingly collect or solicit information from, market to, or accept services from children.
Lost or Stolen Information: You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen or used without permission.
Changes to this Policy: Each time you visit the Site or use the Services, the current version of the Policy will apply. When you use the Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We may require you to affirmatively assent to a revised version of this Policy as a condition of continuing to use the Site or our Services.
Contact us: Your information is controlled by EquityZen Inc.If you have any questions or concerns about how your information is handled you may contact us at:
At EquityZen INC (the "Company"), your privacy is very important to us. The purpose of this privacy policy (this "Policy") is to provide you with a description of the types of information we collect about you when you visit the EquityZen web site located at equityzen.com, and associated sub-domains (the "Site"), and how we use that information. By visiting or using the Site you agree to the provisions of our Terms of Use and this Policy. If you do not agree to the terms of this Policy, please do not use or access the Site or use the Services (defined below). This Policy only applies to information collected while you are on the Site. For more information on how the Site may redirect you to other web sites, please see the "Links and Redirection to Third Party Sites" section below.
We collect and store information that you voluntarily provide to us as well as data related to your Site visit.
In some areas of the Site, we request or may request that you provide personally identifiable information, including your name, address, email address, telephone number, username, and other information from which your identity is or may be discernible. We collect personally identifiable information from our users at several different points on the Site. We will also allow you the opportunity to provide information identifying yourself as an investor or borrower and, if you are a borrower, the amount you will be seeking, your desired target rate, the intended use of funds and loan duration. Such information is collected for the purpose of contacting you with information regarding prospective investment or borrowing opportunities (as applicable) based on your specified interests (the "Services"). It is solely up to you whether you furnish such information. If you do provide such information, you are thereby consenting to the use of that information in accordance with the policies and practices described in this Policy. This information may be stored on our servers, and on the servers of third party service providers.
In addition, during your visit we automatically collect certain aggregate information and analytical data related to your Site visit (see "Use of Cookies" below). Aggregate information is non-personally identifiable or anonymous information about you, including the date and time of your visit, the IP address of your computer or mobile device, your computer or mobile device browser information, the Internet address that you visited prior to and after reaching the Site, the name of the domain and host you used to access the Internet, the type of mobile device you use, your mobile device's unique device ID and the features of our Site which you accessed. This data is in no way associated with your personally identifiable information.
We use collected information to make available and to improve our high standard of reliable services. We use such information to:
We do not sell or rent personally identifiable information to third parties who are not affiliates of the Company. Information that you provide will not be shared with any other user of the Site without your consent. We may disclose personally identifiable information to appropriate affiliates of the Company, including strategic alliance affiliates and third party service providers, to respond to a request for service or to provide information about available products or services. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of users of our Services, the geographic distribution of our users, the amount of information located and/or removed, etc.).
We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our Terms of Use. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity's contact information to victims who request it.
We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action. If the subpoena seeks information about an identified user or limited group of users, we'll make reasonable business efforts to contact the user(s) before providing information to the party that requests it. We cannot guarantee that we will be able to contact the user(s) in all cases, whether because of a time limit, court order, inability to effectively contact a user, or for any other reason.
We may disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our products, Services and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect your information and are prohibited from using your personally identifiable information for any other purpose.
As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this Policy unless and until it is amended.We share your information with our parent, subsidiaries and joint ventures to help coordinate the Services we provide to you, enforce our terms and conditions, and promote trust and safety.
We may share aggregate (non-personally identifiable) information with certain third parties such as advertisers, national industry organizations, and prospective affiliates. In addition, we reserve the right to disclose aggregate information and personally identifiable information to third parties as required or permitted by law and when we believe that disclosure is necessary to protect our rights.
If you choose to take advantage of the Services by signing up as either an investor or borrower, you will receive periodic emails regarding opportunities which, based on the information you provide, may be of interest. If you no longer wish to receive our communications, you may unsubscribe by following the instructions included in each communication.
"Cookies" are simple text files stored on your computer for use by a browser. Certain Site features may only be available through the placement of a cookie. We may use "cookies" to assist in data collection and to track visitor Site usage and trends to help us better serve you. The use of cookies is a standard practice among Internet web sites; most Internet browsers permit a user to accept, decline or delete cookies. This Site works with a first party cookie that collects anonymous traffic data at the Site.
We use persistent cookies to make it easier for you to navigate the Site. Specifically, we use persistent cookies to track whether you are logged into the Site. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file.
We set a persistent cookie to store how you came to the Site and what listings and content you view. Persistent cookies also enable us to track and target the interests of our users to enhance their experience on the Site.
If you reject cookies, you will still be able to view the Site, but your ability to use some areas of the Site, such as automatically-generated recommendations, will be limited. You will be unable to log into the Site if you reject cookies.
Some of our business partners (e.g., analytical tracking software providers) use cookies and tracking technologies on the Site. We have no access to or control over these cookies or tracking technologies. This Policy covers the use of cookies on equityzen.com and by us only and does not cover the use of cookies or tracking technologies by any such business partner.
You may review, correct, update or change the personally identifiable information you provide at any time. If you would like to edit your personally identifiable information please contact us for assistance at hello@equityzen.com.
The Site may contain links to third party web sites and may redirect you to third party web sites ("Third Party Sites"). These sites include, among others, service providers who have a relationship with the Company.
Third Party Sites are not under the control of the Company, and the Company is not responsible for such Third Party Sites, including without limitation the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness thereof, any link contained therein, or any changes or updates thereto. The inclusion or access to Third Party Sites does not imply an endorsement thereof by the Company, or of the provider of such content or services, or of any third party web site. The Company reserves the right to terminate any link or linking program at any time.
Please be aware that when you enter a third party web site, any information you provide, including financial information, is subject to the terms of use and privacy policy of that site.
This Site and our Services are not directed to person under the age of 13. If you become aware that you child has provided us with personal information without your consent, please contact us at hello@equityzen.com. We do not knowingly collect or solicit information from, market to or accept services from children. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child's account.
Each time you use the Site, the current version of the Policy will apply. Accordingly, when you use the Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We will not materially change our policies and practices to make them less protective of customer information collected in the past without the consent of affected customers.
You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen, or used without permission.
This Policy is governed by the laws of the State of New York, without giving effect to any principles of conflict of law.
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