PRIVACY POLICY

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VENTUREFIN PRIVACY POLICY
 

VentureFin SPC (“we” or “us”) respects the privacy of consumers’ personal information and our practices reflect our commitment to the safeguarding of personal information.

 

We collect personal and financial information about you that you provide while you use the Site.  We collect this information during the registration process.  There is some information that Investors and Entrepreneurs must provide and other information that they may provide voluntarily.  We will keep some of this information private and will display some to other Users.  We shall always let you know which information will be made public and which information will be kept private.  Additional information may be gathered during your use of the Site, whenever you choose to provide it.  We also collect information about your loan account balance and payment history.

 

Certain personal information must be supplied during the Investor and Entrepreneur registration processes, as indicated below, in order to:


a) enable registered users to login to the site;
b) determine Entrepreneur eligibility for loans through our proprietary credit scoring process;
c) verify Entrepreneur and Investor identities;
d) identify Entrepreneur and Investor ability to invest, obtain loans or transfer equity by verifying that they are at least 18 years of age;
e) guard against potential fraud; and/or
f) conduct due diligence through partnering with a third party compliance firm.

 

This basic personal information to be provided includes:

 

1. Your name (participant registration).
2. Your email address (participant registration).
3. Your date of birth (Entrepreneur / Investor registration).
4. Your home address and telephone number (Entrepreneur / Investor registration).
5. Your fiscal number (Entrepreneur / Investor registration).

 

When you register as an Entrepreneur, we will use this basic personal information to pull a credit report from a credit bureau to determine your creditworthiness as well as to help Investors assess your Proposal in the context of your overall financial situation.  

 

When you register as an Entrepreneur, we will use this basic personal information to determine Entrepreneur eligibility, as well as to help Investors assess your equity or debt funding request in the context of your overall financial situation.  

 

We will also use your information to facilitate transactions such as:


1. generating public profiles on the Site;
2. assigning you a VentureFin rating based on your credit history and financial evaluation;
3. assigning you a VentureFin qualification based on the type of interest being offered to Investors;
3. enabling our financial services partners to implement automatic payments and fund transfers;
4. contacting Entrepreneurs and Investors if there is a problem completing a transaction they requested or to discuss a problem with their accounts; and/or
5. maintaining regular communications with Entrepreneurs and Investors concerning transactions, such as requesting information or assistance, submitting a loan request, making payments, transferring funds, or other actions..

 

When you register as an Investor, we will request personal information in order to facilitate such activities as:

 

1. Generating a public Investor profile on the Site;
2. Enabling our financial services partners to implement fund transfers and the receipt of borrower payments;
3. Contacting the Investor if there is a problem completing a transaction the Investor requested or to discuss a problem with the Investor’s account.
4. Maintaining regular communications with the Investor as may be necessary, such as transferring funds or submitting orders.

 

In addition, we gather names and email addresses of individuals who contact us through our Site with questions.   We collect this information for the sole purpose of responding to such inquiries.

 

Finally, we collect information relating to Entrepreneurs’ and Investors’ computers and visits to our Site, including IP addresses, geographical locations, browser types, referral sources, length of visits, and page views through the use of log files.  We use this aggregated information in the administration of our Site to improve its usability and to evaluate the success of particular marketing/advertising campaigns, search engine optimization strategies and other marketing activities.  We use non-identifying and aggregated information to help optimize our Site based on the needs of our Users.  No personally identifiable information about any individual User is collected.

 

We retain this information to satisfy legal requirements such as recordkeeping, tax and credit reporting, as well as for purposes of fraud prevention, audit and data integrity.

 

Referral Activities

 

Users may refer other individuals to the Site or directly to their loan listings via email.   If this referral occurs independently of our Site or a partner's site, we do not track the referral other than as a unique page view.  Since we do not collect any information from the referring party or the recipient of the external email referencing our Site, we do not capture or store any information about either party.  If individuals refer each other to our Site or to their loan listings via a partner's site, we will store and track information about the referring and receiving parties only long enough to determine the effectiveness of our marketing activities which contributed to the referral.

 

Users may electronically forward a link or page to another individual by clicking the "Email" link.  Users must provide their own list of recipients in order for these emails to be sent.  This information is not used for any other purpose and we do not store the names or email addresses of such other individuals..  These are ‘one-time’ only emails initiated by associated individuals related the recipients, and the recipients are not added to any mailing list or contacted by VentureFin apart from this specific ‘one-time’ email.

 

Users can also refer associates and other individuals to the Site by completing a simple form to generate an email invitation.  In this case, the email invitations do not track back to any particular loan request, and the sender will not know whether you are an Entrepreneur, Investor or a Participant.  This information is stored for the sole purpose of sending this one-time email and tracking the success of our referral program.  In the case where a bonus is offered to a Participant in return for the referral, we will only retain the information about the referred parties to properly credit the account of the Participant initiating the referral.  The information is not used for any other purpose.

 

Communications From Us

 

When Entrepreneurs and Investors register on our Site they will receive emails that confirm specific actions they requested.  These notifications are typically sent to notify them of a change in status, or for legal or security purposes.  For example, they will receive notifications confirming their registration, the successful verification of email addresses and bank accounts, and the successful submission of loan requests and equity transfers’ availability and investment orders; they will receive notifications regarding certain changes to legal agreements and required loan or equity transfers and privacy disclosures; and they will receive progress updates on the status of loan requests or equity transfers and investment orders.  These are transactional notifications that they generally cannot opt out of receiving.  We may also send responses to emails sent to us, if appropriate or applicable.

From time to time, we will also send user surveys, requests for user feedback regarding user experience and site operations, newsletters, event notifications, group leader notifications, or marketing offers from us or on behalf of our marketing partners.  The completion of these surveys or requests for feedback, receipt of these newsletters or notifications, or acceptance of any offer is strictly voluntary.  If you do not wish to receive these surveys or user feedback emails, newsletters, notifications or marketing offers, please opt out of the type of email you do not wish to receive at the ‘Notifications’ link located in your account profile.


How and When Your Information Is Shared

 

Information is shared with other parties in the following ways:


1. Required and optional information about Entrepreneurs and Investors is displayed on public profiles that Participants can update at any time; certain information is optional and they may choose not to supply it and may remove the optional information at any time.
2. Personal, but not personally identifiable, information about Entrepreneurs is contained in loan listings and equity transfer listings that can be viewed by all Users;
3. Financial and credit information about Entrepreneurs is displayed to qualified Investors on loan listing and on equity transfer pages; and is contained anonymously in loan and equity transfer data files available through VentureFin's Developer Tools and Marketplace Performance pages.
4. Information is shared directly between Users and potential users.  Information shared directly by Users and potential users may contain personally identifiable information.
5. If a loan or an equity transfer originated through our platform creates interest from the Investor, we may provide that Investor with personally identifiable, financial and credit information about the Entrepreneur.  Information may be shared to meet any applicable law, regulation, legal process or enforceable governmental request, for the purposes of limiting fraud.
6. Information may be shared with a number of trusted partners that perform vital functions as part of our operations.

 

For privacy purposes, Entrepreneurs and Investors remain anonymous on the Site and are identified only by their chosen screen names.  However, Entrepreneurs have public profiles and loan and equity transfer listings on the Site that display their relevant information and data to any Users who view these pages.  

 

Investors also have public profiles on the Site that display personal information that they have opted to include.  VentureFin shall not be responsible or liable in any way whatsoever for any personal information that Entrepreneurs or Investors may choose to reveal about themselves in their screen names, loan requests, or public profiles, and any consequences that may occur as a result of actions by third parties taken through the use of such information without your consent.  

 

We may share your 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 your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order, or legal process.

 

VentureFin works with a number of trusted partners that perform vital functions as part of our operations, including platform administrators, loan servicers, credit bureaus, compliance firms, collection agencies, electronic payment service providers, quality assurance agents, and companies that distribute our emails for us or collect survey information from our customers.  Information is shared with these third parties only to the extent necessary for us to process the transactions you initiate or to perform other specific services, like collections.  Our partners are also required to keep your information private and secure and use their own respective privacy safeguarding processes.

 

It is necessary to allow prospective Investors to see information as they evaluate Entrepreneur requests.  The financials and credit information obtained from a credit bureau is contained anonymously in loan data files available through VentureFin's Developer Tools and Marketplace Performance pages.

 

VentureFin will disclose to Entrepreneurs and Investors the information VentureFin reasonably determines to be adequate to protect the privacy of the parties.

 

If an Entrepreneur successfully receives a loan or equity funding through VentureFin we will display status information about such loan or funding to Investors.  Your loan or equity funding information tracks back to the Entrepreneur through its screen name, so it is important that Entrepreneur chooses a screen name that will protect its anonymity.

 

Entrepreneurs and Investors should not choose a screen name that resembles their actual name or that of any other person.  Furthermore, they should not include their name or personally identifiable information in their loan or equity request.  In the case of a loan, their payment performance information such as late payments, collections activity or any other instances of delinquency will be displayed to your Investors (and potential Investors).

 

Where Personal Information May be Accessed

 

Entrepreneurs and Investors may access all of their personal, and personally identifiable, information that we collect online and maintain, by logging in to their accounts and going to "My Account > Settings".  This section of the Site is password-protected to better safeguard your information.  As a registered User, you may update your password, email address, secret question, screen name, physical address, phone numbers, bank account information, and Participant page at any time on the Site, and if you need to change any other information in your profile or request that we delete/remove your information, you can contact us at [xxxxx@xxxxx.com].  To protect your privacy and security, you must contact us at [xxxx@xxxx.com] to make changes to your sensitive account information.

 

We will retain and use your information as needed to provide you our services, to comply with our legal obligations, to resolve disputes, to enforce our agreements or as otherwise required by law.

 

Information Collection

 

Cookies are text files created by websites that store information on Entrepreneurs’ and Investors’ computers, such as their preferences when visiting such websites.  VentureFin uses cookies when you sign in, to keep track of your personal session, including some account identifiers so that we can ensure that you are the only person making changes to your account. Cookies are also used to gather statistical data, such as which pages are visited, what is downloaded, the ISP's domain name and country of origin, and the addresses of sites visited immediately before and after coming to our Site, as well as your "click stream" activity (meaning, the paths taken by visitors to our Site as they navigate from page to page) and transactional attributes in accordance with information you voluntarily submit in the course of using our Site.

 

This anonymous data is aggregated for analysis to ensure proper functioning of our Site, in terms of navigation and usability, as well as to evaluate the effectiveness of our marketing efforts.  We also use cookies to track your activity on our Site as a unique person.  We use session ID cookies to make it easier for you to navigate our Site.  Session ID cookies expire when you close your browsers.  We use a persistent cookie that remains on your hard drive for an extended period of time, so that we can recognize you when they return to our Site.  You can remove persistent cookies by following directions provided in your internet browser's ‘help’ file; however, because we use cookies for our sign-in functionality, if you choose to disable cookies you will not be able to log on to the Site.  All of this information is stored in an encrypted fashion for security reasons, and no personal information about you is stored.

 

We do not acknowledge "do not track" signals or other similar mechanisms whereby a visitor to a website requests that it disables collection of information about the visitor's online activities over time and across different websites.  Additionally, we may permit affiliates and partners to collect such information.  For instance, we might do so to track the source of traffic to our Site.

 

We use third-party tracking services (for example, Google Analytics) that use cookies to track non-personally identifiable information about visitors to our Site in the aggregate (such as page views and referral page information to track the success of our marketing efforts to bring people to our Site as well as overall site performance).  

 

Links to Other Sites

 

We may offer links to partners' sites.  We make the decision to provide links to these sites based on the quality of information provided at the time the links are enabled, and we make every effort to monitor the continuing quality of content provided on these sites. However, these external sites are not subject to this Privacy Policy.  Furthermore, VentureFin has no control over the content of these sites.  We suggest the consultation of the privacy policies on these sites before Entrepreneurs and Investors provide them with any personal information.

 

Social Media Features

 

Our Site includes social media features and widgets ("Features"), such as the Facebook Like button. These Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Features to function properly.  Features are either hosted by a third party or hosted directly on our Site.  Your interactions with these Features are governed by the privacy policy of the company providing it.

 

VentureFin's Security Policy

 

Venture Fin takes steps to safeguard Entrepreneurs and Investors personal, and personally identifiable, information through physical, electronic and operational policies and practices.  All data is considered confidential.  Data can only be read or written through defined service access points, the use of which is password-protected.  The physical security of the data is achieved through a combination of network firewalls (there is no direct communication allowed between the database server and the internet) and servers with hardened operating systems are all housed in a secure facility.  Access to the system, both physical and electronic, is controlled and limited.  We do not permit access to of your fiscal number(s), bank account information, or credit card information via the Site.  Further, we also equip our servers with Secure Socket Layer (SSL) certificate technology to ensure that when you connect to our Site you are actually on our Site.  SSL also ensures that all data entered into the Site is encrypted.  To verify that SSL is being used, look for the key or padlock icon on your browser.  For further encryption protection, we use a XXX-bit secure browser for logins and transactions.

 

Identity Theft

 

Although VentureFin has a stringent process in place to prevent unwanted parties from using  fraudulently acquired identities, the possibility of fraudulent activity is nonetheless possible. VentureFin will work with law enforcement authorities to track down and prosecute persons who have committed identity theft.  If you are an Investor who suspects that you've invested with a party claiming an identity belonging to a person who has committed identity theft, please contact your local law enforcement first, and then email customer support and include the all the relevant information and the reason you suspect identity theft.  VentureFin shall conduct its own internal good faith investigation of the allegations and notify you of the results as they become available, as well as any actions we may have taken or plan to take.

 

Secure Data Center

 

We store all sensitive financial information on a secure data center that adheres to [XXXXXX] standards.  Physical access to the data center is strictly controlled and we use the most effective technology available to us to effectuate threat prevention.

 

Passwords

 

At a minimum, we require the use of both numbers and letters in your password.  We have also instituted secure steps by which Entrepreneurs and Investors can regain access to their accounts should they forget their passwords, including the use of a security question.  Your password is not known to any employee or third party with whom we may partner, and we will never ask for your password.  You should never share their passwords with anyone, and if you ever receive an email purporting to come from VentureFin that asks for your password, you should immediately report this to VentureFin at [-].

 

What Entrepreneurs and Investors Can Do

 

To protect your account, we send automatic notifications confirming certain actions taken on your account.  We do this for your own protection so that you can be sure that no one else is making changes to your account without your knowledge.  However, the security offered through these notifications can be undermined if other individuals have access to your account.


VentureFin will never ask for your login information.  In general, you can protect yourself against phishing by never providing personal or login information via an email.

 

Changes to This Policy

 

If we make updates to this Privacy Policy, we will update it with the changes and revise the ‘last updated’ date posted at the bottom of this Privacy Policy.  Any updates to the Privacy Policy become effective when we post the updates on the Site.  If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on the Site prior to the change becoming effective.  Your use of the Site following the update to the Privacy Policy means that you accept all such new terms and policies.

 

For additional information, or if Entrepreneurs and Investors have any questions regarding this policy or the privacy practices at VentureFin, please submit your questions or comments directly to [xxxxxxx@xxxxx.com] via email.  Any personal information you submit will be used solely to respond to your requests.

 

You can also send questions or comments to:

 

VentureFin SPC
c/o
Attn: Compliance Department
Address
Email
Phone: