Privacy Policy
This Privacy Policy explains how EquityBrix, Inc., a Delaware state corporation, and its subsidiaries and affiliated companies (“EquityBrix,” “we,” “our,” and/or “us”) collects, uses, and discloses information about you when you visit and use www.EquityBrix.com (“Website”), our online Application (“Application”), and the related services we provide (collectively, the “Services”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our Website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.
Collection of Information
1. Information You Provide To Us
a. Registration. When you register to use our Services, we ask you for your name, email address, phone number, username, password, accreditation status and other registration related information. We may also ask for documentation to verify your accreditation status.
b. Profile Information. Once registered to use our Services, we collect additional information from you to create your profile. For example, we ask you for your phone number, your company name and company address, job title, industry, date of birth, and an image for your profile picture, investment preferences and other profile information.
c. Investment Account. If you create an investment account through our Services, we ask you for account type (e.g. individual, joint, IRA), legal investing account name, taxpayer ID number or Social Security Number, account address, ACH information or SWIFT account number, accreditation verification, as well as additional investment account members and information.
d. Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our customer support team, we will receive your name, email address, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you participate in one of our surveys, we may receive information about you relating to the subject matter of the survey. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
e. Marketing Information. We may ask you for your preferences for receiving marketing communications and details about how often you wish to receive such information.
f. Verify Your Identity. For security purposes, we may request additional information from you to verify your identity. For example, we may collect your social security number, date of birth, address, citizenship information, and copy of your government-issued identification. We may also use two-factor authentication to protect your login information.
g. Funding and Distribution Information. If you invest through our marketplace, we will collect your bank account information to transfer money to your investments and fulfill your distributions and capital returns.
2. Information We Collect When You Use Our Services
a. Device Information. We receive information about the device and software you use to access our Services, including IP address (which may provide us with your general location information), web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.
b. Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, your EquityBrix website browsing history, your EquityBrix application usage history, the investments you make, your comments and communications to EquityBrix and our real estate Sponsors, and the dates and times of your visits and comments.
c. Information from Cookies and Similar Technologies. We, our service providers, our real estate Sponsors, and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may 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 Services. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. You may also see the Your Choices section below for more options. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
3. Information We Receive From Third Parties
a. Credit Reporting Agencies. If you are a Sponsor of an offering or register for an investment account through our Services, we may receive information about you from credit reporting agencies to comply with applicable laws and industry standards, such as Know Your Business (“KYB”) or Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”). For example, we may receive your pass/fail status of KYC and AML. We may also receive information from credit reporting agencies to verify your bank accounts and other ownership information.
b. Registration Information. You can log in to the Services using third party credentials such as LinkedIn or Google. These services will 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 our registration form.
c. Other Third Parties. We may receive additional information about you from third parties such as data or marketing partners and combine it with other information we have about you. For example, we may receive your name, e-mail address, and general location information derived from your IP address from marketing partners to learn more about demand for current and prospective users.
4. Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address.
Use of Information
We use the information we collect for the following purposes:
1. To provide, maintain, improve, and enhance our website, Application, or Services;
2. To personalize your experience on our Services such as by providing tailored content and recommendations;
3. To understand and analyze how you use our Services and develop new products, services, features, and functionality;
4. To better understand how users’ access and use our Site, the Application, and Services, both on an aggregated and individualized basis;
5. To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
6. To provide you with investment opportunities to match your individual investment goals;
7. To administer your investor account;
8. To provide investment services;
9. To carry out, record your investment transactions in our database and on a blockchain (aka, a distributed ledger database);
10. To facilitate offers on behalf of other Users or third parties.
11. For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
12. To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports;
13. To send you text messages and push notifications;
14. To facilitate transactions and payments;
15. To detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of EquityBrix and others;
16. To debug, identify, and repair errors in our Services;
17. For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
18. For other purposes for which we provide specific notice at the time the information is collected.
How we share the information we collect
We share your information in the following circumstances or as otherwise described in this policy:
1. Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
2. Investment Sponsors. If you indicate an interest in making an investment through the Services, we will notify the party or parties offering the investment and their affiliates (the “Issuer”) of your interest and may notify other Users or Investors with whom you have consented to share information. Note that, upon your admission to an investment offering (a “Company”), the Issuer may share information including, but not limited to, member names, initial capital contributions, and distribution amounts with other members of the Company. Please refer to the terms of the Company's operating agreement and relevant state law for additional detail.
3. Social Networks And Other Online Services. Our Services may allow you to, upon your direction, share information with social networking services, such as Facebook and Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third-party platforms and your settings on that platform. We encourage you to review their privacy policies.
4. Integration. If you choose to use integrations we offer on our Services, such as sharing your location through our Google Maps integration, we may share certain information with our integration partners for the purpose of delivering the service integrations.
5. Marketing. We do not rent, sell, or share information about you with non-affiliated companies for their direct marketing purposes, unless we have your permission.
6. Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting Google Privacy & Terms. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, your browsing history, the searches you conduct, people you follow, investments you make, your comments, any content you post, clickstream data, advertising interactions, and the dates and times of your visits.
7. Advertising Partners. We may work with third-party advertising partners to show you ads that we think may interest you. If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking.
8. As Required By Law And Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.
9. Merger, Sale, Or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.
10. Consent. We may also disclose your information with your permission.
11. Aggregated And De-Identified Information. We also share aggregated or de-identified information that cannot reasonably be used to identify you.
Analytics
The Services, including the text, graphics, images, photographs, videos, illustrations and other content contained therein, are owned by EquityBrix or our licensors and are protected under both United States and foreign laws. Except as explicitly stated in our Terms of Service and this policy, all rights in and to the Services are reserved by us or our licensors. Subject to your compliance with the Terms of Service and this policy, you are hereby granted a limited, nonexclusive, nontransferable, non-sublicensable, revocable license to access and use our Services for your own personal, noncommercial use. Any use of the Services other than as specifically authorized herein, without our prior written permission, is strictly prohibited, will terminate the license granted herein and violate our intellectual property rights.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
Transfer of Information to the United States and Other Countries
EquityBrix is headquartered in the United States, and we have operations and service providers in the United States. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
Security
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
Children's Privacy
We do not knowingly collect, maintain, or use personal information from persons under 18 years of age, and no part of our Service is directed at children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at info@EquityBrix.com.
Your Choices
1. Account Information. You may update and correct certain account information at any time by logging into your account, sending instructions via email at info@equitybrix.com, or writing to 4580 Klahanie Dr. SE, suite 292, Sammamish, WA 98029. If you wish to delete your account, indicate that in the instructions, but note that we may retain certain information as required by law or for our legitimate business purposes.
2. Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.
3. Communication Preferences. You may opt out of receiving promotional emails from EquityBrix by following the instructions in those communications or by contacting Investor Relations at investor@EquityBrix.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Changes to this privacy policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.
Contact Information
If you have any questions about this Privacy Policy, please contact us at info@EquityBrix.com.
Transfer of Information to the United States and Other Countries
EquityBrix is headquartered in the United States, and we have operations and service providers in the United States. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
Contact Us
If you have any questions about this Privacy Policy, please contact us at investor@equitybrix.com
