Updated June 9th, 2017 (“Effective Date”).
Non-Personally Identifiable Information
FundPaaS collects non-personally identifiable information from you regarding your usage of our website ("Non-Personally Identifiable Information"). Non-Personally Identifiable Information may include, without limitation, website pages viewed, articles, presentation and videos viewed, time spent using certain features of the website, demographic data such as server locations, cookies existing on your computer, search criteria used and results, date, time, connection speed, and other information which does not specifically identify you. Regardless of whether you register for an account or submit an application, FundPaaS collects Non-Personally Identifiable Information using various technologies, including, but not limited to, cookies and server logs.
FundPaaS (or our service providers, such as Google Analytics) may also collect web surfing data related to your use of the Website. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Website. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. FundPaaS may, for example, use this aggregated information in the administration of the Website to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Website based on the needs of our users.
Personally Identifiable Information
FundPaaS also collects personal information, business information, and financial information from you and your business when you visit the Website. The majority of information is collected during the registration and application processes, as well as when you sign up for an account, make an investment, verify your identity or accredited investor status, provide payment instructions or send us an email through the FundPaaS website which may enable us to identify you personally ("Personally Identifiable Information" and collectively with the Non-Personally Identifiable Information, the "Data")). While some items are optional, most are required for legal or security purposes. You may choose to provide additional information during subsequent visits to the Website, but keep in mind that some of this information will be required if you wish to partake in the Services. We may request additional information to help verify your identity or for other purposes. We may also obtain information about you from third parties, such as identity verification services or credit bureaus.
FundPaaS will also gather the names and email addresses of users who contact us through the Website with questions about our company or lending platform. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested to do so, as in the case of job applicants who submit resumes.
Important Information About Procedures for Opening a New Account
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We will also ask to see your driver’s license or other identifying documents.
Investor registration and securities offerings applications will require you to provide personal data and business data. Personal data typically includes your name, email address, home address and phone number, date of birth, social security number and/or tax identification number, employer and job title. FundPaaS uses this data to: (i) enable you to log in to the Website; (ii) establish your ability to view offering materials and to make investments through the Website (for U.S. residents, such ability is restricted to “accredited investors” with a certain level of annual income or net worth); (iii) determine your credibility to partake in lending opportunities; (iv) verify that you are at least 18 years of age; (v) guard against potential fraud; (vi) contact you if there is a problem with your account; and (vii) maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other company updates.
Financial Data (for Investors)
When you subscribe to make an investment in one of our offerings on the platform, you will again be asked for your personal data. You will also be required to provide financial data, such as your bank routing number and bank account number, to enable us or our broker-dealer partners to utilize your bank account to originate funds transfers and make subsequent investment disbursements to you.
When you register to conduct a securities offering through our Website, you will be required to provide personal data, as well as extensive personal and business disclosures related, directly or indirectly, to your business, business associations, criminal history, business plan, business relationships, financial information, business risks, personal risks, etc., in accordance with all applicable laws and regulations, including but not limited to SEC rules and regulations, FINRA rules and regulations, federal and state laws, mandates, rules, and regulations.
FundPaaS may also collect and store information, which could include Non-Personally Identifiable Information or Personally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.
We may also have access to your Personally Identifiable Information when you log into our website through certain third party social networking services, including Facebook, LinkedIn, Twitter and Internet Chat ("Third Party Services"). We encourage you to carefully review the privacy policies of any Third Party Services from which you access our website.
How and When Your Information Is Shared With Other Parties
FundPaaS does not sell or rent personal information about its users for marketing purposes.
Usage & Sharing of Data
Toward these ends, you consent to our use and disclosure of any information submitted to us via the FundPaaS website, or information collected when you access the FundPaaS website in any manner, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information. Your investment profile information may, in a generic way, be made publicly available for use on the “Statistics” page of the Website or in other summaries of aggregate investment data.
FundPaaS will use Non-Personally Identifiable Information and Personally Identifiable Information:
- to market our products and services to you,
- to provide services and products requested by you,
- to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our website and other services,
- to meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members,
- to engage in any other lawful activities we believe are consistent with the foregoing, and
- to protect against legal liability.
We may provide any of these services through third parties, which may necessitate sharing Personally Identifiable Information and Non-Personally Identifiable Information with them.
If you provide Data for a certain reason, we may use the Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Data you provide to answer your question or resolve your problem. FundPaaS may also use your Data and other personally non-identifiable information collected through our website to help us improve the content and functionality of our website, to better understand our users and to improve our services. As user of our services we will send you administrative communications that are reasonably necessary to our services, such as billing or service notifications.
If you are a potential business borrower or issuer, then as part of the onboarding process, we may verify information contained in the business application / onboarding documents and in other documents required in connection with issuing securities under all applicable laws and regulations, such as Reg. A+, Reg. Crowdfunding, 506b, 506c or intrastate exemptions, at any time, for any lawful purpose. Your information may also be shared with any investor to whom we may ask to invest in your business; any investor to whom we may issue, sell, or resell securities associated with your business; and to any loan guaranty insurer. Such data may include, but is not limited to, employment history and income; bank, money market, and similar account balances; credit score and credit history; copies of income tax returns; and consumer report information. Such data may be provided to users of the platform to aid in their decision to commit funds.
Notifications and Communications from Our Website
FundPaaS will send you email notifications from time to time. Some notifications are required elements of your transactions on our platform, such as confirmations of particular actions you have taken. These mandatory notices are sent typically to notify you of a change in status. For example, you will receive a notice when you are confirmed as an investor.
We also send out notices that are required for legal or security purposes. For example, certain notifications are sent for your own protection to ensure that another person cannot make a change to your account without your knowledge. In other cases, these notifications involve changes to various legal agreements or Website policies. Generally, you may not opt out of such service-related emails.
When you register as an investor, you will receive emails that confirm specific actions you requested. These will include emails to which you must respond to complete your registration and notifications confirming your registration. Thereafter, you will receive emails when a new investment opportunity is offered, as well as updates concerning the progress of the funding of such offering and/or other relevant information. If you make an investment through the Website, FundPaaS (or a designated escrow agent) will also send you confirmations of the investment as well as occasional updates as to the status of that investment and the timing of distributions relating to that investment.
We may also send you responses to emails you send us, if appropriate. From time to time, we will also send user surveys, requests for user feedback regarding user experience and Website operations, or marketing offers from us or from us on behalf of our marketing partners. Completing these surveys, answering requests for feedback, or accepting any offer is strictly voluntary. If you do not wish to receive these surveys, user feedback emails, and/or marketing offers, please opt out in any offer email you receive from us.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name and other information. If you wish to update or delete your testimonial, please contact us at firstname.lastname@example.org.
Social Media Features
You can log into our Website using sign-in services such as Facebook, Google, Twitter, or LinkedIn. These services authenticate your identity and provide you the option to share certain personal information with us, such as your name and email address to pre-populate the user sign-up form.
Blog & Other Exclusions
If you use our blog on the Website, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of this forum and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in this forum. To request removal of your personal information from our blog, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Additional Sharing of Data
FundPaaS employs or contracts with other third parties, companies, or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification, accreditation/financial/credit verification, electronic document signing, payment storing and processing, sending postal mail and e-mail, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to your information, including Non-Personally Identifiable Information or Personally Identifiable Information, as needed to perform their functions or services, and may not use it for other purposes. Our partners are legally required to keep your information private and secure.
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. We further reserve the right to disclose any of your 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 Website or our services, or to protect the rights, property or personal safety of FundPaaS, its users, issuers, or others.
FundPaaS may disclose your Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of FundPaaS, (iii) act in urgent circumstances to protect the personal safety of users of the website or the public against fraud or other harm, or (iv) protect against legal liability.
Where You Can View and Correct Your Information
The FundPaaS website is not intended for use by children, especially those under age thirteen (13) years of age. No one under age thirteen (13) years of age is allowed to use the site, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children or teenagers under the age of thirteen (13). If you believe that a minor has disclosed Personally Identifiable Information to FundPaaS, please report this to us immediately by emailing us at: firstname.lastname@example.org.
Links to Other Websites
Applicable Law and Jurisdiction
The Website may be accessed by users located outside the United States. If you choose to use the Service 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 that by providing your personal information on or through the Website then you consent to that transfer.
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this notice at any time. Any changes or updates will be effective immediately upon posting to the Website and sending a notification to all registered users via email regarding such update. You should review this notice regularly for changes, and can determine if changes have been made by checking the Effective Date at the top of this document. Your continued use of our website following the posting of any changes to this notice means you accept such changes.
We limit access to the personal information we have about you to those employees who have a legitimate business need to access such information. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. The Website is built upon a secure infrastructure with multiple layers of protection, and we use industry-standard encryption technologies to safeguard your information.
Users are required to identify and authenticate themselves prior to accessing sensitive portions of the Website. Generally, identification and authentication take place through the use of your username and a password and/or while logging in with one of our technical support staff.
Notifications of Security Systems Breach
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 Website 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.
Take Precautionary Measures
You can take several precautions to protect the security of your computer and personal information. For instance, you can use a well-chosen password and restrict access to your email account. You can also install and regularly update antivirus and firewall software to protect your computer from external attacks by malicious users. When you are finished with a session on the Website, be sure that you log out and close the browser window.
You should also be aware of fraudulent attempts to gain access to your account information through "phishing," whereby scammers try to bring unsuspecting people to a Website by using a genuine-looking email purporting to be from a legitimate company. Sometimes, either in the email itself or on this fake Website, scammers will ask for login information to gain access to people's accounts and withdraw their money.
FundPaaS will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go the Website directly. You might also make it a habit to check the URL of a Website to be sure that it begins with the correct domain. In the case of FundPaaS, you should always ensure the URL begins with https://www.FundPaaS.com.