PRIVACY POLICY

Initially Effective February 26, 2023

Last Updated May 25, 2023

This privacy policy ("Privacy Policy") describes how Wefunder Inc., Wefunder Portal LLC, Wefunder Advisors LLC, Wefunder Investments Ltd, Wefunder EU B.V., Capitalize Technologies LLC and Capitalize Advisors LLC (together, “Capitalize”, and collectively with Wefunder("Wefunder" "we" "us" or "our") collect, use, and share information about users of our websites, including wefunder.com and capitalize.co, our Apps and our associated services (collectively, our "Site" and "Services"). We are committed to protecting and respecting your privacy. To understand more about the roles we carry out in handling personal information, please see the Contact Us section. By using our Site and Services, you acknowledge you have read and understood this Privacy Policy and our practices described below. Your use of our Site and Services is also subject to our Terms of Use. Please note that any user information shared with one of our entities may be shared among the other Wefunder and Capitalize entities.

Information We Collect about you

Information you provide us.

When you use our Site, our Services or otherwise choose to interact with us, we receive personal information about you such as when you register for and create a profile on our Site. Personal information means information from which you may be identified both directly (from that information alone) and indirectly (when different pieces of information are combined).

We may collect and process the following personal information from you:

Name and contact. This information may include your name, address phone number, email address, social media handle that you provide if you fill in forms on our Site or otherwise contact us.
Account login details. If you choose to sign up and create an account, we will collect your name, chosen username and password.
Account profile details. On your Wefunder or Capitalize profile, you can make additional optional personal details available including a photo, biography, links to a personal website or blog, details of your skills, investment goals and interests, and other similar information.
Identity details.We may need to collect certain information to verify your identity, including your name, date of birth, applicable tax or other national issued identifiers, Social Security number, and /or other legally recognized identity documentation such as your driver’s license.
Investor details.To ensure compliance with legal requirements, we may need to collect your net worth, income and other information necessary to verify your investor accreditation or sophistication status.
Investment transaction details. If you choose to invest in an offering through our Site, we will collect payment information from you, such as financial account information or payment card information, and we may collect information to verify your income, such as a bank statement or W-2 form. Please note that we do not store your payment card information, but we do store other financial information. If you choose to add an investment entity to your Account profile, we will also collect information about the entity.
Founder business details. If you would like to raise funding for your business with our Site and Services, we will collect information about your business, including other officers and stockholders, business financial statements, your fundraising terms, and payment and banking information.
Compliance information. We may need to request information in connection with business legal and regulatory risk checks.

We also collect information when you post questions or comments on our Site, send or receive direct messages from other users or when you contact us, including via email, or social media.

We will indicate whether information is required or voluntary on the Site

When you visit our Website.

We may automatically collect certain information when you use our Site including:

Interaction information about your use of our Site, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site including the actions you take, the pages or other content you view, search for or otherwise interact with, content response times, and the dates and times of your visits.
Technical and device information,such as you IP address used to connect your device to the internet, operating system information and web browser and /or device type, version and time zone setting and language.
Location information,we may derive your regional location from your IP address.
Cookies and similar technologies,When you visit our Site, we and our service providers collect certain information through the use of "cookies" and other similar technologies to better understand how our users navigate through our Site, learn what content is being viewed and administer and improve our Site and Services. Cookies are small text files that web servers place on an internet user's device that are designed to store basic information and recognize your browser. We use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site. We use cookies /and other similar technologies either alone or in combination with each other to create a unique ID which corresponds to you. For more information see the 'Use of cookies and other technologies' section below.

Information from other sources.

Social Media, If you make your personal information publicly available, such as information posted to social media sites when you tag us, or otherwise interact with our social media channels and posts, for example by liking a post, we may collect personal information such as your social media profile name and picture or content you post, like and reactions to your posts.
Third Party Integration, If you decide to register through or otherwise grant access to a third party social networking or authentication service that we may make available ("Integrated Service"), such as Facebook, LinkedIn, Twitter or Angellist, we will collect certain personal information that you have provided to the Integrated Service (such as your name, email address, photo and other information you make available via the Integrated Service) and an authentication token from the Integrated Service. The personal information collected from the Integrated Service may be used to register you on our Site and to provide some of the features of our Site. You may revoke our access to your account on the Integrated Service at any time by updating the appropriate settings in the account preferences of the respective Integrated Service. You understand that certain features of our Site may not be available to you if you choose to remove our access to your account with the Integrated Service.
In order to provide the Services on our Site, including verifying your identity and other information you provide us or in conducting any required checks (including in the context of checks against international sanctions, exposed persons or export control registers), we collect information about our users from third parties, such as Blockscore, LexisNexis, and Onfido, and combine it with other information we received from or about our users.

How we use Information we Collect

We may use the information we collect for the following purposes:

Information you provide us.

To take steps to enter into any contract or carry out obligations arising out of our terms with you including to:
- administer your account with us
- process payments and investments
- notify you about changes to our Services
- keep a record of transactions
To comply with legal obligations to which we are subject including:
- identity and/or business verification checks
- record keeping requirements
- cooperating with regulatory authorities
Where necessary in our legitimate interests
- In providing the information you request from us, including responding to any queries you have submitted
- in managing corporate risk, security and compliance operations
- to enforce this Privacy Policy or other terms to which you have agreed, and to protect the rights, property or safety of us, our Site our users, or any other person.
With your consent, where required, for example to send you our marketing communications.
Unless we are required to obtain your consent, we will use this information in our legitimate interests where we have considered these are not overridden by your rights to:
- provide, improve and personalize our Site
- monitor and analyze usage trends and preferences
- keep our Site and Services safe and secure
- measure or understand the effectiveness of our communications or advertising to you and others and to deliver relevant advertising to you

Information from other sources

Unless we are required to obtain your consent, we will use this information in our legitimate interests where we have considered these are not overridden by your rights:
- We may use information obtained via social media channels for our own analysis and marketing purposes.

Necessary Cookies

Intercom – we use intercom so that users of our Site can communicate with our customer support team via our live chat function
Stripe - we use Stripe to handle payment processing. Stripe uses cookies to authenticate users and protect against fraud.
Vitesse - we use Vitesse to handle payment processing. Vitesse may use cookies to authenticate users and protect against fraud.
Plaid – We use Plaid to connect and verify banks accounts.
Sift – We use Sift to help us detect spam and fraud.
Wefunder First Party Cookies – We use these cookies for user login.
Cloudflare – We use this for attack and spam prevention.

Analytics cookies

Google Analytics cookies enable us to recognise and count the number of visitors and to see how they engage with our Site content and features. This helps us for our legitimate interests of improving the way our Site works, in order to provide you with the most relevant content. For example, ensuring that users are finding what they are looking for easily. You can find more information on how Google uses data from these cookies including about how to opt-out at the below links:
www.google.com/policies/privacy/partners/. https://tools.google.com/dlpage/gaoptout
Fullstory – Analytics cookies enable us to see a visual representation of how users are interacting with our Site. This helps us for our legitimate interests of fixing technical issues and improving the operation of our Site.
https://www.fullstory.com/legal/privacy-policy https://www.fullstory.com/optout/
Hubspot – we use Hubspot to track engagement by visitors to the Site and to manage enquiries from our Site and our relationships with our founders and investors for our CRM platform.
https://legal.hubspot.com/privacy-policy
Sendwithus Analytics – This is a service provided by Techdrop Labs as part of email distribution services that monitor user engagement with our emails and the performance of our email campaigns
https://www.dyspatch.io/privacy-policy/#sendwithus

Advertising cookies

Google advertising cookies are used to show you our ads on other websites across the Internet. These ads may be directed to you based on your past visits to our Site and your use of our Site. You can find more information on how Google uses data from these cookies including about how to opt-out at the below links:
www.google.com/policies/privacy/partners/. https://adsettings.google.com/

Social networking cookies

These cookies help us to manage our social media, including enabling you to share content and enabling us to understand how you interact with us.

Facebook – we use Facebook cookies and pixels to help deliver our advertising on Facebook. This means you may see our ads when you use Facebook because you have visited and then visited Facebook. These cookies also tell us if you come to our Site after having clicked on an advertisement on Facebook. We also work with Facebook to deliver our ads to Facebook users who match against certain criteria which Facebook identify. Please visit your Facebook privacy settings to learn more and see here: https: //www.facebook.com/policy.php
Twitter – we use Twitter cookies to deliver our ads on the Twitter platform to you and to those other Twitter users who might be interested in our Services based on their online activities including on the Twitter platform. Please visit your own Twitter privacy settings to configure how ads are displayed to you and also see here https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads.

You can opt out of our service provider's use of cookies for directed marketing purposes by visiting the US Network Advertising Initiative's opt-out page or in Europe the European Interactive Digital Advertising Alliance (EDAA) programme at www.youronlinechoices.eu . Please note that after opting-out, you may continue to see ads from those service providers, but they will not be based on your past activities.

You may choose to disable some cookies. The effect of disabling cookies depends on which cookies you disable. Please note that if you delete, or choose not to accept, all cookies from our Site, you may not be able to utilize certain features of our Site to their fullest potential. You can also consult your web browser settings to learn the proper way to modify cookie settings.

How We Share Information We Collect

We may make information available to:

Businesses You Invest In.

We may share your information with businesses that you invest in. The information about you that we share with the business you invest in may include your public profile information and your address, email address and tax/national issued identifier or Social Security number including for compliance, tax and accounting purposes.

Other Users and the Public.

Please note that your profile page is viewable by other users and the public. For information on privacy settings available to you, please see the "Account Settings Choices" section below.
Any comments or information you submit or share on public areas of the Site, such as questions for founders, your bio, or a description of your business, can be read, collected or used by other users and the public. Please consider carefully the information you choose to submit or share on the public areas of our Site, such as investment pages or your public profile.
We also share your information with other users when you send or receive direct messages from other users.
Affiliates and Banks. In order to provide the services on our Site, we may share your information with other third parties, such as portfolio companies, investment banking firms, accountants and similar entities.
We use service providers to provide certain services to us and on our behalf and in accordance with our instructions. This includes in supporting our Services, in particular those providing Site data hosting services, fulfilment services, distributing any communications we send, fraud detection, facilitating feedback on our Services, advertising, marketing, analytics services and providing IT support services from time to time.
Payment processing providers who secure payment and bank transfer processing services. Note your payment card details are securely processed by the provider and not held by us.

We only provide our service providers and partners with information necessary for them to perform these services. Our analytics providers may collect information about your online activities over time and across different online services when you use our Site.

Change of control.

In the event that Wefunder or Capitalize is merged or sold, or in the event of a transfer or sale of some or all of our assets, we may disclose or transfer information we collect in connection with the negotiation and/or conclusion of such a transaction.

Other disclosures.

We may disclose information about you to third parties if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies or terms of service, (c) to protect the security or integrity of our Site and Services, (d) to protect the property rights, and safety of us, our users, or the public, (e) to respond in an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.

Your Account Settings Choices

You can update the information you provided to us by accessing your account settings. Through your account settings, you can also hide some portions of your profile from other users or the general public on the Internet as well as hide your profile from search engines that collect information from our Sites.

You can also change your stated marketing preferences and opt out of promotional email communications at any time by clicking on the unsubscribe link in an email you received from us. You can also update your communication preferences through your account settings on our Site.

Children’s Privacy

Our Site is not intended for children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If we learn that we have collected the personal information from a child under the age of 13, we will take steps to delete the information. If you are aware that a child under 13 has provided us with personal information please contact us at [email protected].

International Data Transfers

Your personal information will processed in accordance with this policy in the U.S. and Europe. Where you are resident in Europe, we handle your personal information outside of the European Economic Area (EEA) and where we facilitate access to or transfer of your personal information outside of the EEA we will take steps to handle your personal information subject to appropriate safeguards, for example, implementing approved standard contractual clauses where appropriate as the laws regarding processing of personal information may be less stringent than the laws in the EEA.

Third parties that we work with may also process your personal information in the U.S. and/or facilitate the transfer of or access to your personal information outside of the U.S. We will take steps to require them to process your personal information subject to appropriate safeguards, for example, implementing standard contractual clauses where appropriate.

How Long we Keep your Information

We retain personal information:

for as long as we are legally required or otherwise permitted to meet our reason for collection (for example, for as long as we are providing Services to you) and as necessary after that to anticipate, resolve or defend any issues.
relating to any account or transactions with us, in order to meet our contractual obligations to you and and/or any transaction to identify any issues, resolve any legal proceedings and for tax and accounting purposes.

We may also retain aggregate information for research purposes and to help us develop and improve our services.

Your Rights

Depending on the country you access our Site and Services from, you may have the right under certain circumstances:

to find out what information we hold about you;
to be provided with a copy of your personal information;
to request the correction or deletion of your personal information;
to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
to object to the further processing of your personal information, including the right to object to marketing (as mentioned in 'Your Account Settings Choices' section);
to request that your provided personal information be moved to a third party.
You can un-install our App which will stop information being collected from the App. You may use the standard un-install processes as may be available for your mobile device.
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time.

If you wish to exercise any of the rights listed above that are available to you, you can do so at any time by contacting us and the data protection team will respond according to the applicable law.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority.

The Dutch Data Protection Authority is the supervisory authority in the Netherlands in respect to Wefunder EU B.V. and can provide further information about your rights and our obligations in relation to your personal information, as well as deal with any complaints that you have about our processing of your personal information.

Changes to Our Privacy Policy

Please revisit this page periodically to stay aware of any changes to our Privacy Policy, which we may update from time to time. If we modify our Privacy Policy, we will make it available on our Site and indicate the effective date.

In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access our Site for the first time after such material changes are made. Your continued use of our Site after the revised Privacy Policy has become effective indicates that you have read and understood the current version of our Privacy Policy.

Contacting Us

Where you visit our Site, invest or seek to raise funding, then for European law purposes, the Wefunder or Capitalize entity responsible for the type of Services or offering you engage with or invest with and who will be identified to you in the context of that Service, offering or investment engagement will be a controller.

Wefunder Inc., a controller which hosts the Site and from which global and strategic decisions are made as the parent company of the Wefunder business, 1885 Mission St., San Francisco, CA United States

Capitalize Technologies LLC, a controller which administers the Site and from which global and strategic decisions are made as the controller of the business related to capitalize.co, 1885 Mission St., San Francisco, CA United States

Wefunder EU B.V., our European HQ, and a controller in respect of European offerings and investors, Strawinskylaan 411 WTC Toren A, 1077XX Amsterdam, the Netherlands.

Wefunder Investments Ltd, 8th Floor Block E, Iveagh Court, Harcourt Road, Dublin 2, Ireland.

If you have any questions, comments or concerns about our Privacy Policy, please email us at [email protected]

PRIVACY POLICY

Information We Collect about you

Information you provide us.

When you visit our Website.

Information from other sources.

How we use Information we Collect

Information you provide us.

Information from other sources

Use of Cookies and other Technologies

Necessary Cookies

Analytics cookies

Advertising cookies

Social networking cookies

How We Share Information We Collect

Businesses You Invest In.

Other Users and the Public.

Change of control.

Other disclosures.

Your Account Settings Choices

Children’s Privacy

International Data Transfers

How Long we Keep your Information

Your Rights

Changes to Our Privacy Policy

Contacting Us