Privacy practice

PRIVACY POLICY

LAST UPDATED October 5, 2016

OUR POLICY

Welcome to the web site www.infobrij.com (the “Site”), which is owned and operated by Infobrij LLC (hereinafter, “Infobrij”, “we”, “us”, and/or “our”).  The law requires that we ask for certain information in order to perform the services we offer and we are committed to protecting any personal or financial information that you provide to us.  This Privacy Policy provides information about us and the services we provide (the “Services”) to visitors to the Site and those who use the Services, including, but not limited to, parties using the Site to offer investments (each, an “Issuer”) and investors using the Site to evaluate and consummate an investment (each, a “User”, and collectively, “Users”). This Privacy Policy sets forth the provisions that apply to Infobrij’s collection and use of information, including personally identifiable information and financial information (“Personal Information”) from Users.  If you have any questions regarding this Privacy Policy, you should contact us at info@infobrij.com.

By using the Site and/or any Services, you accept the terms of this Privacy Policy as it may be updated from time to time in our sole and absolute discretion.

INFORMATION WE COLLECT

When you visit the Site or utilize the Services, we may collect Personal Information and other information from you as follows:

Personal Information That You Provide.  We collect Personal Information from you when you voluntarily provide it to us, such as when you (i) register for access to the Services (for example, contact information such as your name, email address, phone number, mailing address); (ii) complete certain forms on the Site; (iii) upload or submit any material through the Site, (iv) request any information or contact us with inquiries; or (v) elect to use certain Services (for example financial information such as bank account numbers, your Date of Birth and the last 4 digits of your social security number). This Personal Information is required to transact business, to communicate with you, to verify your identity and to fulfill legal and regulatory requirements.

By voluntarily providing us with any of your Personal Information, you are giving Infobrij permission to use and store it consistent with this Privacy Policy. We may also obtain your Personal Information from transactions you enter into with us or with other Users, or from third parties such as credit reporting agencies. If we combine or associate information about you from other sources with Personal Information that you provide directly to us, we will treat the combined information as Personal Information in accordance with this Privacy Policy.

Non-Identifying Information.  When you interact with Infobrij through the Site or the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you.

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. Infobrij may store such information itself or such information may be included in databases owned and maintained by Infobrij affiliates, agents or service providers.  We may use such information and pool it with other information to track, for example, the total number of visitors to the Site, the number of visitors to each page of the Site, the domain names of our visitors’ Internet service providers, and how our Users use and interact with the Services. Also, in an ongoing effort to better understand and serve our Users, Infobrij conducts research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us.  This research may be compiled and analyzed on an aggregate basis. We may share this non-identifiable and aggregate data with our affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.

In operating the Site, we may also use a technology called “cookies.” A cookie is a piece of information that the computer that hosts the Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, the Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Information except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.

The use of cookies by any of our affiliates or service providers is not covered by this Privacy Policy. We do not have access or control over these cookies. Our partners use session ID cookies to make it easier for you to navigate the Site and use the Services.

HOW WE — USE YOUR PERSONAL INFORMATION

We use the Personal Information you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Information you provide to answer your question or resolve your problem. Also, if you provide Personal Information in order to obtain access to the Services, we will use your Personal Information to provide you with access to such Services and to monitor your use of such Services. We also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud.

In addition, Infobrij and its subsidiaries and affiliates may also use your Personal Information and other non-identifiable information collected through the Site (collectively, “User Information”) to, among other things, improve user experience, customize content for our users in order to make the Site more simple to use, and to help us identify any other issues with respect to the Services or a User’s use of the Site or Services. Infobrij and its subsidiaries and affiliates may also use this information to communicate with you regarding the Services. If you object to our collection or storage of any User Information mentioned above (and any additional information we may choose to gather) you should not use the Site.

ACCURATE INFORMATION; EMAIL

You are solely responsible for helping us to maintain the accuracy and completeness of your personal and other information. If your User Information changes, or if you no longer desire to use the Services, you may correct, update, or amend the information by making the change in your registered account settings page or by emailing us at info@infobrij.com. We will respond to your request within 30 days.

We will retain your User Information for as long as your account is active or as needed to provide the Services.. We will retain and use your User Information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements.

When you sign up for the Services or our newsletter(s) or other communications, we will send periodic emails to you regarding the Services or to tell you about services we believe will be of interest to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at info@infobrij.com.  We may also send you emails for other purposes, including providing information related to your personal transactions and service-related announcements and notifications.  It is your responsibility to ensure that you maintain a current email address with Infobrij and to notify us if there are any changes.

SHARING OF PERSONAL INFORMATION

Infobrij limits the sharing of your Personal Information and strives to keep your Personal Information private and confidential. We do not sell, license, lease or otherwise disclose your Personal Information to any unaffiliated third party for any reason, except as set forth in this Privacy Policy.

If you indicate an interest in making an investment through the Site, we will notify the Issuer of your interest and will provide your Personal Information to the Issuer.

Additionally, if Infobrij undergoes a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.

Infobrij also works with (among others) providers of hosting services for the Site, electronic signature providers, and electronic payment service providers.  We may engage third parties to help us carry out certain other internal functions such as account processing, client services, or other data collection relevant to our business.  Examples of third parties might include those that perform data processing, reporting, tax documentation, custody or escrow services.  Personal Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections.  Our partners are legally required to keep your Personal Information private and secure.

We may share Personal Information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose Personal Information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any Personal Information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our Services, or to protect the rights, property or personal safety of Infobrij, its users, issuers, or others.

SAFEGUARDING — USER INFORMATION

The security of your Personal and/or User Information is important to us, and we take commercially reasonable steps to safeguard such information. These steps and procedural safeguards are in line with industry standards and practices.  However, despite these efforts, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure, and therefore Infobrij cannot ensure or guarantee the security of your Personal and/or User Information nor do we make any representation or warranty regarding the security of your account. If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Site and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

LINKS TO OTHER WEBSITES

This Privacy Policy applies only to the Site. The Site may contain links to other web sites not operated or controlled by Infobrij (the “Third Party Sites”). The policies and procedures described in this Privacy Policy do not apply to the Third Party Sites. The links from the Site to Third Party Sites do not imply that Infobrij endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

INTERNATIONAL — USERS

The Services may be accessed and/or used by users located outside the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States and by providing your Personal Information on or through the Services you consent to that transfer.

CHILDREN’S PRIVACY

Infobrij does not knowingly collect Personal Information from children under the age of 13 without the consent of their legal guardian. If you are under the age of 13, please do not submit any Personal Information through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on this Site without their permission. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with the Services or Infobrij has received any Personal Information of that child without your consent, you may contact us, and we will endeavor to delete that information from our databases.

PUBLIC INFORMATION

Please keep in mind that any information you post on portions of the Site or the Services that are open to the public, including but not limited to our blog (if any), will be public information available to anyone. Information that you provide in these areas may be read, collected and used by others who access them. Accordingly, you should exercise caution when deciding to disclose your personal information in these areas. To request removal of your personal information from these publicly accessible areas, contact us at info@infobrij.com. In some cases, we may not be able to remove your personal information and we will let you know if this is the case and why.

UPDATES AND CHANGES TO PRIVACY POLICY

We reserve the right at any time to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update or modification will be effective immediately upon posting on the Site. We encourage you to periodically review this page for the latest information on our privacy practices.

OTHER TERMS AND CONDITIONS

Your access to and use of this Site is subject to the Terms of Use [infobrij.com/toupp].

CONTACTING INFOBRIJ

If you have questions or comments about this Privacy Policy or any other aspect of the Site or Services, please feel free to contact us by email at info@infobrij.com.