Information you provide to us. To establish an account and access our Services, we'll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide your bank account number if you'd like to make an investment at Crowdfund My Deal), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.
If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.
We may collect the following types of information from you:
• Personal Identification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
• Formal Identification Information: Government issued identity document such as Passport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
• Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation), personal identification information for all material beneficial owners.
• Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, and/or tax identification.
• Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
• Employment Information: Office location, job title, and/or description of role.
• Correspondence: Survey responses, information provided to our support team or user research team.
• Audio, electronic, visual and similar information, such as call and video recordings.
• Information we collect from you automatically. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:
• Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
• Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.
• For example, we may automatically receive and record the following information on our server logs:
• How you came to and use the Services;
• Device type and unique device identification numbers;
• Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
• How your device interacts with our Sites and Services, including pages accessed and links clicked;
• Broad geographic location (e.g. country or city-level location); and
• Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.
We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.
Information we collect from our affiliates and third parties. From time to time, we may obtain information about you from our affiliates or third-party sources as required or permitted by applicable law. These sources may include:
Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our Services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others.
Crowdfund My Deal may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.
Most of our core Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, Crowdfund My Deal must identify and verify customers using our Services in order to comply with anti-money laundering laws across jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provide against third-party databases and public records. When you attempt to use a bank account to make an investment at Crowdfund My Deal, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk as required under applicable law. If you do not provide personal information required by law, we will not be able to process your investment.
We process your personal information in order to help detect, prevent, and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss.
6.4 To provide Crowdfund My Deal's Services
For example, the Services use your information to:
1. identify you when you sign-in to your account;
2. enable us to provide you with the Services;
3. send you information we think you may find useful or which you have requested from us;
4. present projects or opportunities to you when you use the Services which we believe will be of interest based on your geographic location and previous use of the Services;
5. notify an Issuer of your interest in the event you indicate an interest in making an investment with the Issuer through the Services;
6. administer your account with us;
7. enable us to contact you regarding any question you make through the Services;
8. analyze the use of the Services and the people visiting to improve our content and Services;
9. use for other purposes that we may disclose to you when we request your information.
10. We may make certain automatically collected information about your interactions and activities on the Services, such as the business or investment areas of interest to you or you have invested in, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users.
6.5 To provide Service communications
From time to time (i) we will send you as a user of the Services email relating to your personal transactions but will keep these emails to a minimum; (ii) you will receive certain email notifications (forwarded messages, etc.) for which you may opt-out; (iii) we may send you service-related announcements on rare occasions when it is necessary or proper to do so; (iv) if you email us directly, we may email you back and keep records of all correspondence; and (iv) we may send you emails from time to time letting you know about special promotions, featured investments and other Crowdfund My Deal news. It is your responsibility to ensure that you maintain a current email address with Crowdfund My Deal, and notify us if there are any changes.
6.6 To provide customer service
6.7 To ensure quality control
6.8 To ensure network and information security
6.9 For research and development purposes
6.10 To enhance your experience
6.11 To facilitate corporate acquisitions, mergers, or transactions
6.12 To engage in marketing activities
In the event you indicate an interest in making an investment through our Site, we will notify the Issuer of your interest and will provide your Personal Information to the Issuer.
6.13 For any purpose that you provide your consent.
Section & Purpose of Processing
Legal Bases for Processing
(6.2) To enforce our terms in our user agreement and other agreements (6.4) To provide Crowdfund My Deal's Services (6.5) To provide Service communications (6.6) To provide customer service (6.7) To ensure quality control
Based on our contract with you or to take steps at your request prior to entering into a contract.
(6.9) For research and development purposes (6.10) To enhance your experience (6.11) To facilitate corporate acquisitions, mergers, or transactions (6.12) To engage in direct marketing activities
Based on our legitimate interests. When we process your personal data for our legitimate interests we always ensure that we consider and balance any potential impact on you and your rights under data protection laws.
(6.1) To maintain legal and regulatory compliance (6.3) To detect and prevent fraud and/or funds loss (6.8) To ensure network and information security
Based on our legal obligations, the public interest, or in your vital interests.
(6.10) To enhance your experience (6.12) For any purpose to which you consent
Based on your consent.
We may share your information with third-party identity verification services in order to prevent fraud. This allows Crowdfund My Deal to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used in connection with the provision of identity verification and fraud prevention services.
Additionally, we may need to share your information in continuance of the transaction for which you have voluntarily utilized our services. The ways in which we share that information immediately follows.
Potential Disclosure of Subscriber Information to Related Transaction Parties; Ongoing Compliance with Governmental Requirements. The company(ies) sponsoring an investment project (collectively, the "Sponsor"), lenders relating to the investment project, or other parties involved with the investment and related transactions (collectively, "Related Transaction Parties") may require that Crowdfund My Deal, the Manager, or any of their respective affiliates provide such Related Transaction Parties with the names, investment amounts, and other information regarding the various investors in a financing offering, notwithstanding the usual privacy policies of Crowdfund My Deal or any of its affiliates. You hereby expressly consent and agree that any of Crowdfund My Deal, the Manager or any of their respective affiliates may provide such information (which may include, without limitation, Social Security numbers or similar identifying information, evidence of your qualification as an "accredited investor," or other information related to your involvement with an investment project) to any such Related Transaction Parties requiring such information as part of the consummation of, or continued participation in, the investment project or the related transactions contemplated hereunder, as Crowdfund My Deal or any of its affiliates may deem appropriate in its or their sole and absolute discretion.
The Department of the Treasury, the Internal Revenue Service, and other governmental authorities may from time to time impose certain compliance or reporting requirements that may require Crowdfund My Deal or any of its affiliates to request from you additional financial or personal information. These regulations may require increased due diligence, compliance activity, or reporting on the part of Crowdfund My Deal or any of its affiliates. You hereby warrant that you will, upon request, supply to Crowdfund My Deal or any of its affiliates all information reasonably necessary or advisable to carry out such functions or requirements.
With financial institutions with which we partner to process payments you have authorized.
With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:
• Network infrastructure
• Cloud storage
• Payment processing
• Transaction monitoring
• Document repository services
• Customer support
• Internet (e.g. ISPs)
• Data analytics
• Information Technology
With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
With companies or other entities that purchase Crowdfund My Deal assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.
With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our User Agreement or any other applicable policies.
We may share personal information about you with our Affiliates as a normal part of conducting business and offering Services to you.
We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the US and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Full credit card data is securely transferred and hosted off-site by payment vendors in compliance with Payment Card Industry Data Security Standards (PCI DSS). This information is not accessible to Crowdfund My Deal or Crowdfund My Deal staff.
However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.
• Personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.
• Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
• Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).
• Recording of our telephone calls with you may be kept for a period of up to six years.
• Information collected via technical means such as cookies, webpage counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.
Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and property; (d) where the request is frivolous or vexatious, or for other reasons.
Access and portability. You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another entity.
Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by Crowdfund My Deal that is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Crowdfund My Deal's processing based on consent before your withdrawal.
Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing or transferring your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Automated individual decision-making, including profiling. Crowdfund My Deal may rely on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.
Marketing communications. You can opt-out of receiving marketing communications from Crowdfund My Deal. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services. We will only contact you by electronic means (email or SMS) based on our legitimate interests, as permitted by applicable law, or your consent. If you do not want us to send you marketing communications, please go to your account settings to opt-out email a request to email@example.com.
For users in the European Economic Area, the United Kingdom and Switzerland: To the extent we can rely on legitimate interest under the applicable law, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. We will contact you by electronic means for marketing purposes only if you have consented to such communication. You may raise such objections with regard to initial or further processing for purposes of direct marketing, at any time and free of charge.
How to make a privacy request. You can make privacy rights requests relating to your personal information by going to your Privacy Rights Dashboard or, if you cannot access the Dashboard, by contacting us at firstname.lastname@example.org. Our Privacy Rights Dashboard also allows you to set your communication preferences and make individual rights requests relating to your personal information. We strongly encourage you to make any individual rights requests through the Privacy Rights Dashboard because it ensures that you have been authenticated already (based on the KYC information you have provided to open your account and by providing the necessary login credentials and multi-factor authentication to access the account). Otherwise, when we receive an individual rights request via other intake methods, we may take steps to verify your identity before complying with the request to protect your privacy and security.
• the categories of information we disclosed to third parties for the third parties' direct marketing purposes during the preceding calendar year; and
• the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this California Privacy Rights section. This section describes the categories of personal information Crowdfund My Deal has collected, the categories of personal information Crowdfund My Deal has disclosed, and a description of California residents’ rights.
Categories of Personal Information Collected
The chart below described the categories of personal information Crowdfund My Deal has collected in the preceding 12 months, the sources and purpose of such collection, and the parties to whom the information was shared for business purposes.
Personal Information Category (corresponds to categories in CCPA §1798.140(o)(1))
Sources of Personal Information and Why We Collect this Information (see Section 6 above for more information)
Disclosure of Personal Information (see “Why We Share Personal Information With Other Parties” heading above for more information)
(A) Identifiers such as Personal Identification Information
Information you provide us; Information collected from third parties; Why we collect this information: see Section 6, subsections 6.1, 6.2, 6.3, 6.4, 6.5, 6.6, 6.8, 6.9, 6.11, and 6.12
- Third party identity verification services - Financial institutions - Service providers - Professional advisors - our Affiliates
(B) Customer records such as signature
Information you provide us; Information collected from third parties; Why we collect this information: see Section 6, subsections 6.1, 6.2, 6.5, 6.6, and 6.11
- Third party identity verification services - Financial institutions - Service providers
(C) Protected classifications under California and federal law, including gender, age and citizenship
Information you provide us; Information collected from third parties; Why we collect this information: see Section 6, subsection 6.1
- Third party identity verification services - Professional advisors
(D) Commercial information such as records of services purchased, obtained, or considered
Information you provide us; Information we collect from you automatically; Information collected from third parties; Why we collect this information: see Section 6, subsections 6.3, 6.4, 6.5, 6.6, 6.8, 6.9, 6.10, 6.11 and 6.12
- Third party identity verification services - Financial institutions - Service providers - Professional advisors - our Affiliates
(E) Biometric information
Information you provide us; Why we collect this information: see Section 6, subsection 6.1
- Third party identity verification services - Financial institutions
(F) Usage Data
Information we collect from you automatically; Why we collect this information: see Section 6, subsections 6.2, 6.3, 6.4, 6.6, 6.7, 6.8, 6.9, 6.10, and 6.12
- Third party identity verification services - Service providers - Professional advisors - our Affiliates
(G) Online Identifiers
Information we collect from you automatically; Why we collect this information: see Section 6, subsections 6.1, 6.3, 6.9 and 6.12
- Third party identity verification services - Service Providers
(H) Sensory data, such audio, electronic, visual information
Information you provide to us; Why we collect this information: see Section 6, subsections 6.3, 6.4, 6.5 and 6.7
(I) Professional or employment-related information
Information you provide us; Information collected from third parties; Why we collect this information: see Section 6, subsections 6.1, 6.12
- Third party identity verification services - Service providers - our Affiliates
(J) Inferences about preferences, characteristics, predispositions, etc.
Information you provide us; Information we collect from you automatically; Why we collect this information: see Section 6, subsections 6.9, 6.10, 6.12
- Service providers - Professional advisors - our Affiliates
California Residents’ Rights
Under the CCPA, you may have the following consumer rights. Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the CCPA:
For personal information collected by us during the preceding 12 months preceding your request that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. Crowdfund My Deal will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you a different level or quality of services.
To the extent we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. Crowdfund My Deal does not sell your personal information in its ordinary course of business and will never sell your personal information to third parties without your explicit consent.
Should Crowdfund My Deal engage in any of the activities listed in this section, your ability to exercise these rights will be made available to you in your account settings. You can exercise your rights by going to your Privacy Rights Dashboard or contacting us at email@example.com so that we may consider your request.
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise your rights, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.
If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. To do so, you must: (1) provide that authorized agent written and signed permission to submit such a request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. We will respond to your authorized agent's request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4121 to 4130. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.
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