When you sign up to participate on the Uniting Capital Site, you may be asked to provide information such as your full legal name, address and date of birth, along with other personal information that is required to verify your identity and fulfill our legal and regulatory requirements. This information will also be used to transact your business and communicate with you. From time to time, we may request additional information to help us further assess your needs and preferences.
- We gather and process your Personal Information for a variety reasons, depending on how you interact with our services, including:
- To facilitate account creation and authentication and otherwise manage your accounts. We may process your information so you can create and log into your account, as well as keep your account in working order.
- To deliver and facilitate delivery of our services to you. We may process your information to provide you with a requested service.
- To respond to user inquiries/offer support. We may process your information to provide you with the requested service.
- To send you administrative information. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To manage our working relationship with you. We may process your information to manage our working relationship with you and the provision of our services..
- To request feedback. We may process your information as necessary to request feedback and to contact you about your use of our products and services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your indicated preferences. You can opt out of our marketing emails at any time.
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your location, interests, and more.
- To protect our services. We may process information as part of our efforts to keep our services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. Uniting Capital or certain of its subsidiaries may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
The information we collect and maintain about you is provided during the course of using our website, your signing up to receive additional information, or your entering into transactions with private issuers who have engaged Uniting Capital to provide certain services in the context of a private securities transaction through Uniting Capital. Personal Information may come from the following sources:
- Information you provide to us when you fill out documents, complete a form or make a request for services, including, but not limited to, your name, address, age, investment objectives, job title, investment experience, assets and liabilities and/or income details and confidential documentation used to verify those details, telephone number, e-mail address and similar information; and information from your transactions with us, such as your sale proceeds or investment amount. We may collect certain sensitive information, including your social security number or and/or taxpayer identification number, and certain other financial information.
- Automatically collected information when using or navigating our website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. Like many companies, we collect information through Cookies (as defined below) and similar technologies. This information is primarily needed to maintain the security and operation of our services and for our internal analytics and reporting purposes.
- In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, Uniting Capital and certain subsidiaries may obtain information (including without limitation Personal Information) about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties.
We Limit the Sharing of Information
To protect your privacy, we limit the sharing of your Personal Information outside of Uniting Capital. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:
- To help us provide our services to you and/or to improve our services, we engage qualified and reputable third parties to help us to carry out certain functions such as account processing, client services and/or data collection relevant to our business. For example, in each case where you invest through the Uniting Capital Site, we share your Personal Information with Third Party Service (as defined herein) providers in order to perform regulatory-required background checks, with certain technology providers to facilitate document execution, and with third parties that perform execution and clearing services on your behalf.
- As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
- Uniting Capital may share information with our subsidiaries if the information is required to provide the services you request. A subsidiary is a company that we own or control.
- Uniting Capital also reserves the right to disclose your personal information where required by law to federal or state regulatory bodies, law enforcement, self-regulatory organizations or other government authorities, including during routine regulatory examinations. We may also disclose your information as necessary to credit reporting or collection agencies, or to protect our rights or property.
- Notwithstanding the foregoing, all Personal Information shall be dealt with in accordance with any local legislation, including but not limited to the General Data Protection Regulation, to the extent Uniting Capital is or becomes subject to such regulation.
If at any time you choose to purchase a product or service offered by another company, any Personal Information you share with that company will be subject to the privacy policies of the applicable third party companies and will not be controlled by our Privacy Policy. Other than as described above, we are not responsible for the privacy policies or the content of third party sites and/or services (each, a “Third Party Service”) we link to, and have no control of the use or protection of information provided by you or collected by those Third Party services. Whenever you elect to hyperlink to a Third Party Service, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third-party, and you should familiarize yourself with the privacy policy provided by that party.
The following additional information will be of interest to you if you access the Uniting Capital Site and/or one of its subsidiaries’ products or services through one or more of our websites:
- The Uniting Capital Site is built upon an infrastructure with multiple layers of protection. Within the Uniting Capital Site, we use industry standard encryption technologies to help safeguard your information.
- Security is a cooperative effort between us and the users of the Uniting Capital Site. Please remember that your user identification and password are personal to you and should not be made available to any other person. You are responsible for your personal privacy and security practices, including but not limited to management of identification and passwords. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
- “Cookies” are small text files that may be placed on your web browser when you visit our websites. Cookies make it easier for you to navigate our website by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you navigate between our website pages and/or access our services. Authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set, or to prevent cookies from being set. Please note that if you decline to use cookies, you may experience reduced functionality, slower site response times, and declining to use our authentication-related cookies may prevent you from using our website altogether.
- Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Uniting Capital, or by our service providers. This may be accomplished by using cookies, web beacons, page tags or similar tools that are set when you visit our website. Web surfing data and similar information may be shared internally within Uniting Capital and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our websites; and as otherwise permitted by applicable law or regulation. If you are a user, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by Third Party Services, solely in accordance with our instructions.
- The Uniting Capital Site may include social media features (“Features”), such as the Facebook Like button and widgets, such as the “Share This” button or interactive mini-programs that run on this Site (“Widgets”). These Features and Widgets may collect your IP address, which page you are visiting on the Uniting Capital Site, and may set a cookie to enable the Feature or Widget to function properly. Features and Widgets are either hosted by a third party or hosted directly on the Uniting Capital Site. Your interactions with these Features and Widgets are governed by the privacy policy of the company providing it.
We do not knowingly solicit data from or market to children under 18 years of age. By using the services, you represent that you are at least 18. If we learn that Personal Information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at the email address listed below.
We may authorize certain third parties, including, without limitation, Google Analytics, to track usage and collect information about users and their activities on the Uniting Capital Site.
