When you use our services, you're trusting us with your information. We understand this is a big responsibility and work hard to protect your information.
Info & Third Party Services
About This Policy
StartEngine Crowdfunding, Inc. (“StartEngine”) Provides An Intermediary Technology Platform Located At Www.StartEngine.Com (“Platform” Or “Site”) For Prospective Investors To Independently Search And Invest In Securities Offerings On The Site. Unless Indicated Otherwise, All Securities-Related Activity On This Site Is Conducted By StartEngine Capital, LLC (“StartEngine Capital”), An Affiliate Of StartEngine And A SEC-Registered Funding Portal And Member Of FINRA, Or StartEngine Primary, LLC (“StartEngine Primary”), An Affiliate Of StartEngine And A SEC-Registered Broker-Dealer And A Member Of FINRA/SIPC. This Privacy Policy Explains How StartEngine Crowdfunding, Inc., And Its Subsidiaries And Affiliates, Including StartEngine Capital LLC And StartEngine Primary LLC, (Collectively “StartEngine”, “We” Or “Us”) Collect, Use, Share And Protect Your Information.
As explained below, we collect information from users (“you”, “your”, or “User”) in various ways when you interact with our Site. By using our Site, you consent to our collection and use of information as explained in this Privacy Notice and agree to be bound by our Terms of Use. Please note that if you choose to invest in any prospect, project, or offering advertised on our Site, you may be required to agree to a separate agreement, including, but not limited to, new or additional privacy notices or terms of use. Our privacy policy will apply even if you are no longer a customer of StartEngine.
StartEngine collects non-personally identifiable information from you regarding your usage of our Site (“Non-Personally Identifiable Information”). Non-Personally Identifiable Information may include, without limitation, Site pages viewed, websites visited before visiting the Site, frequency of visits, clickstream data, browser type, operating system, organization name, internet connection speed, presentations and videos viewed, time spent viewing pages of our Site or using certain features of our Site, demographic data such as server locations, clickstream data, location services, server location, cookies existing on your computer, search criteria used and results, date and time of access or visits to our Site, frequency of visits to our Site, connection speed, and other information which does not specifically identify you. We collect this information using various technologies (some of which are described below), including, but not limited to, cookies, web beacons, web session variables, server log files, clear gifs, browser plug-ins or add-ons, or Javascript. “Cookies” are pieces of information that may be placed on your computer by a Site for the purpose of facilitating and enhancing your communication and interaction with that Site. A “web beacon,” or “Internet tag” is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a website or in an email which allows a website to record the simple actions of the User opening the Web page that contains the beacon. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.
StartEngine also collects personal information from you (“Personally Identifiable Information”) when you sign up for an account, send us an email through the Site, sign up for or purchase a service through the Site, or make an investment through the Site. Personally Identifiable Information refers to non-public information that identifies you (such as your name, password, age and date of birth, gender, email address, postal mailing address, home/mobile telephone number, social security number/taxpayer identification number, driver’s license number, passport number, Internet protocol (“IP”) address, or other similar identifiers that permit the physical or online identification of a specific individual. We request that you provide us with other personal information, including, but not limited to, your personal or company social media profile, demographic information, financial information about issuers (i.e. valuations, share prices, fundraising goals), financial information about individuals (i.e. net worth) and other information requested from time to time. We 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. However, not all Non-Personally Identifiable Information and Personally Identifiable Information is stored.
We may use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the Site. Google Analytics collects information including, but not limited to, the time of each of your visits to the Site, whether you have visited the Site before, what website referred you to the Site, and what pages you viewed on the Site.
This Privacy Policy does not cover the collection of information by cookies or other methods by such Third Party Services or other third parties, such as our business partners. We do not control how these Third Party Services or third parties collect information or by what means such Third Party Services or third parties may use their own cookies to collect information about you.
StartEngine will use information that you provide consistent with this Privacy Notice. StartEngine will use information that you provide to us, including Non-Personally Identifiable Information or Personally Identifiable Information, to better serve you and enhance your experience with this Site, among other things. This may include having to modify or copy such Non-Personally Identifiable Information or Personally Identifiable Information, or other information such as images or textual content you provide, in order to provide you with a seamless and enjoyable experience.
To this end, you consent to our use and disclosure of any information submitted to or collected by us via your use of this Site, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information unless as provided by law.
StartEngine may use Non-Personally Identifiable Information and Personally Identifiable Information: (1) to market our products and services to you; (2) to provide services and products requested by you; (3) to provide targeted advertisements and messages on our Site to you or other users of our Site; (4) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our Site and other services; (5) to conduct research and analyze data to improve our products, services, and Site; (6) to deliver special offers, updates, newsletters, customer service, and service announcements to you and other users; (7) to verify User information; (8) to comply with any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members; (9) to protect our Site or its Users; (10) to engage in any other lawful business activities that are consistent with the foregoing; and (12) as required by or to comply with law or our Company policies or to protect us from legal liability. We may provide any of these services through third parties, which may necessitate sharing Non-Personally Identifiable Information or Personally Identifiable Information with them.
StartEngine may make your information, including Non-Personally Identifiable Information or Personally Identifiable Information, available on its Site and visible to other Users of or visitors to the Site. For instance, subject to certain preferences and permissions as to visibility you will be allowed to make, information you provide about yourself in response to questionnaires on our Site may be made available to others such as information concerning your status as an accredited investor. As such, other Users of our Site may be able to personally identify you based on your information made available on our Site. As a further example, if you utilize Third Party Services to log into our Site, other Users to whom you may be connected through such Third Party Service may be able to view or follow information about you, including Non-Personally Identifiable Information or Personally Identifiable Information, on our Site.
StartEngine may also employ or contract with other third party partners, 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, electronic document signing, payment storing and processing, sending postal mail and email, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third party partners, companies, or individuals may have access to your information, including Non-Personally Identifiable Information or Personally Identifiable Information, needed to perform their functions or services, and may not use it for other purposes.
StartEngine may also use and disclose Personally Identifiable Information and Non-Personally Identifiable Information to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business; to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Site or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of StartEngine’s business or assets. Any successor in interest to our business would acquire the information we maintain, including Personally Identifiable Information, and may alter the terms of this Privacy Notice.
Except as identified here and subject to user’s ability to opt-out as provided by Regulation S-P, StartEngine does not and will not sell any of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to any third party for purposes of advertising, soliciting, or telemarketing. StartEngine may provide Personally Identifiable Information, including your name, email address, and the date and company of any investment to certain third parties that have referred issuers and investors to StartEngine, or to certain Issuers, including but not limited to issuers in which you have expressed interest. StartEngine may also be required to disclose your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to other companies or entities in the event that StartEngine may be sold or is sold to another company or entity. In that case, your information, including Non-Personally Identifiable Information or Personally Identifiable Information, may be sold or transferred to such acquiring company or entity.
The Site contains links to other websites and services not maintained by StartEngine. In addition, other websites and services may also reference or link to the Site. We encourage you to be aware when you enter or leave our Site, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of other websites or services.
The Site permits Users to communicate with companies and other Users posting information on the Site. We may read, collect and analyze information transmitted between Users for regulatory compliance and marketing purposes. We do not guarantee that information provided by Site visitors or investors is accurate or complete. StartEngine assumes no liability or responsibility for any errors or omissions in the content of its Site.
