PRIVACY POLICY

This Privacy Policy is incorporated by reference into the SharesPost User Agreement (the “User Agreement”). The term “SharesPost Financial,” “we,” and “us” includes SharesPost Financial Corporation and its affiliates and subsidiaries. The Privacy Policy explains how SharesPost may:

  • collect
  • use, and
  • disclose

information we obtain through the “Service” as defined in the User Agreement.

THE SERVICE COLLECTS YOUR INFORMATION

We collect Personal Information when you:

  • register to use the Service;
  • use the Service; and
  • communicate with us.

We may collect information about you from third parties.

We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service.

DURING ACCOUNT REGISTRATION AND MANAGEMENT

You may need to create an account to use parts of the Service. For basic registration, you may need to provide Personal Information, such as your name, email address, and password. To use certain Service functionality you may need provide additional Personal Information, such as your address, date of birth, driver’s license number, social security number, employer information, citizenship, bank account information, financial information, investment activity, account balance, and account history.

USING THE SERVICE

We collect the information, including Personal Information, you post to the Service as you use it, such as investment choices, survey answers, and communications with other users.

THROUGH CUSTOMER SERVICE REQUESTS

We may collect Personal Information, such as your name and email address, from you when you request more information about the Service. We may also collect Personal Information through your communications with our customer-support team.

FROM THIRD PARTIES

We may collect information from our vendors and service providers who provide the Service functionality and other services for us. For example, we may collect information about your account profile and investment activity from the vendors we use to provide the Service functionality. We may obtain information from third parties, such as consumer reporting agencies, to verify the information you provide and determine whether you qualify to use certain parts of the Service. For example, we may use fraud-screening services to verify that your provided information matches the bank account information on file with the bank. We may also collect your credit history and credit score from consumer reporting agencies.

USING COOKIES, AUTOMATIC DATA COLLECTION, AND RELATED TECHNOLOGIES

The Service collects and stores information that is generated automatically as you use it, including anonymous usage statistics. We may correlate such usage statistics with your Personal Information. When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Most browsers allow you to block and delete cookies. However, if you do that, the Service may not work properly.

By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.

HOW SHARESPOST USES YOUR INFORMATION

We use your personal information to

  • facilitate and improve our services;
  • validate the information you provide to use; and
  • communicate with you.

We may use aggregate information for any purpose.

INTERNAL AND SERVICE-RELATED USAGE

We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Service. We may use and retain any data we collect to provide and improve our services.

INFORMATION VALIDATION AND ASSESSMENT

We may use the information you provide to assess its accuracy and your financial condition, including by performing credit checks.

COMMUNICATIONS

We may send email to the email address or call you at the telephone number you provide to us for informational and operational purposes, such as to provide updates about the Service and perform customer service.

MARKETING

We may use information, including Personal Information, to provide online advertising on the Service from us and our affiliates and to facilitate transmittal of information we think may be useful or relevant to you.

AGGREGATE DATA

We may anonymize and aggregate data collected through the Service and use it for any purpose.

SHARESPOST MAY DISCLOSE YOUR INFORMATION

We may share your information:

  • with our third-party service providers;
  • for fraud and misconduct prevention;
  • to comply with legal obligations;
  • to protect and defend our rights and property; and
  • with your permission

We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission or pursuant to a joint marketing agreement with a financial institution.

WE USE VENDORS AND SERVICE PROVIDERS

We may share any information we receive with vendors and service providers retained in connection with the provision of the Service, including third parties that service, maintain, or process transactions and accounts and perform financing, insuring, sale, securitization, assignment, marketing, or other transfers of assets.

FRAUD AND MISCONDUCT PREVENTION

To protect you and us from fraud or other misconduct and to validate the information you have provided to us, we may share information about you with third parties, such as consumer reporting agencies and information verification services, to verify the information you provide. We also may report any debit balance or negative credit information pertaining to your account with consumer and securities credit reporting agencies.

MARKETING

We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission or for joint marketing pursuant to joint marketing agreements with financial institutions. We may allow access to other data collected by the Service to enable the delivery of online advertising on or off this Service or to otherwise facilitate transmittal of information we think may be useful or relevant to you.

AFFILIATED COMPANIES

We may share any information, including Personal Information, with affiliates and subsidiaries, as permitted by law or with your consent.

AS REQUIRED BY LAW AND SIMILAR DISCLOSURES

We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect your, our, or others’ rights, property, or safety.

MERGER, SALE, OR OTHER ASSET TRANSFERS

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of SharesPost’s assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such entities may use or disclose such information.

We may also disclose your Personal Information with your permission.

YOU MAY LIMIT OUR INFORMATION SHARING

You may prevent us from sharing the Personal Information we have collected about you with non- affiliated third parties in certain circumstances. You may not limit the sharing of Personal Information for the purposes of providing the Service, our everyday business purposes, our own marketing, or for joint marketing efforts with other financial companies.

Under the law, you may opt out of our sharing of the Personal Information that we have obtained from third parties, such as your credit reports, with our affiliates, but you may not opt out of our sharing of information we collect related to your transactions and experiences using the Service. You may also opt out of our sharing of Personal Information about you to affiliates and non-affiliates so that they can market to you. We do not currently share the information as described in this paragraph with affiliates or non-affiliates. Therefore, there is no need at this time for you to opt out or take any other steps to prevent such sharing.

INFORMATION RETENTION

We may be required to keep different types of information for varying periods of time according to government regulations and best practices. For example, to comply with regulations imposed by the Securities and Exchange Commission, we may need to keep information for three to six years. We may keep some information longer to meet our needs and those of our customers, even after you close your account.

INFORMATION SECURITY

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at legal@sharespost.com.

INTERNATIONAL USERS

By using the Service, you will transfer data to the United States.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, please send an email to legal@sharespost.com.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

We may revise this Privacy Policy, so review it periodically.

POSTING OF REVISED PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

NEW USES OF PERSONAL INFORMATION

From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

CONTACT INFORMATION

SharesPost Financial Corporation
221 Pine Street, 6th Floor
San Francisco, CA 94104
legal@sharespost.com

ACCOUNT OPEN DISCLOSURES

IMPORTANT INFORMATION YOU NEED TO KNOW ABOUT OPENING A NEW ACCOUNT

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify and record information that identifies each person who opens an account.

This notice answers some questions about SharesPost Financial Corporation’s Customer Identification Program.

What types of information will I need to provide?

When you open an account, your firm is required to collect the following information:

  • Name
  • Date of birth
  • Address
  • Identification number:
    • U.S. citizen: taxpayer identification number (Social Security number or employer identification number)
    • Non-U.S. citizen: taxpayer identification number; passport number and country of issuance; alien identification card number; or government-issued identification showing nationality, residence and a photograph of you.

You may also need to provide your driver’s license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement or a trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA and New York Stock Exchange rules already require you to provide most of this information. These rules also may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.

What happens if I don’t provide the information requested or my identity can’t be verified?

SharesPost Financial Corporation may not be able to open an account or carry out transactions for you. If your firm has already opened an account for you, they may have to close it.

We thank you and appreciate your support of the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.

BUSINESS CONTINUITY PLAN SUMMARY

SharesPost Financial Corporation has developed a Business Continuity Plan describing how we will respond to events that significantly disrupt our business. Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur. With that in mind, we are providing you with this information on our business continuity plan.

Contacting Us:

If after a significant business disruption you cannot contact us as you usually do at (800) 279-7754 or at our email address, info@sharespost.com, you should go to our web site at sharespost.com.

Our Business Continuity Plan:

We plan to quickly recover and resume business operations after a significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption. Our business continuity plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their securities if we are unable to continue our business. Our electronic hosting and compliance providers back up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, we have been advised by these service providers that their objective is to restore their own operations within one hour. Facilitating your transactions could be delayed during and following this period.

Varying Disruptions:

Significant business disruptions can vary in their scope, such as only our firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within one hour. In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within six hours. In either situation, we plan to continue in business, and notify you through our web site at www.sharespost.com, on how to contact us. If the significant business disruption is so severe that it prevents us from remaining in business, we will notify you as soon as quickly as practicable.

For more information:

If you have questions about our business continuity planning, you can contact us at (650) 492-6869.

PUBLIC DISCLOSURE PROGRAM

SharesPost Financial Corporation is required to provide to you information regarding the Public Disclosure Program for investors.

Created by FINRA in 1988, the Public Disclosure Program allows you, the investor, to learn about the professional background, business practices, and conduct of FINRA member firms and their brokers. To request disclosable information under this program, visit the FINRA Regulation Web site at www.finra.org or call (800) 289-9999, a toll-free hotline operated by the NASD.

In addition, please note that there is a Public Disclosure Program Brochure available to you as well. This brochure helps you answer questions pertaining to the Public Disclosure Program, and is available on FINRA’s Web site.

SECURITIES INVESTOR PROTECTION CORPORATION (SIPC)

SharesPost Financial Corporation is required to provide to you information regarding the Securities Investor Protection Corporation (SIPC).

Created by Congress in 1970, the SIPC is an important part of the overall system of investor protection in the United States. The SIPC’s focus is very narrow: restoring funds to investors with assets in the hands of bankrupt and otherwise financially sound troubled brokerage firms.

You can obtain information about SIPC, including obtaining the SIPC brochure, by contacting SIPC by phone, email or regular mail as follows:

Securities Investor Protection Corporation
805 15th Street, N.W. Suite 800
Washington, D.C. 20005-2215
Telephone: (202) 371-8300
Fax: (202) 371-6728
Email: asksipc@sipc.org

In addition, you may also visit the SIPC Web site at www.sipc.org to obtain information.

Important Notice

You are now leaving the SharesPost 100 Fund area of the SharesPost website and proceeding to either a) SharesPost Inc. and its affiliates including SharesPost Financial Corporation, a separate company registered as a broker/dealer with the Securities and Exchange Commission and member of FINRA/SIPC, and SharesPost Investments Management, LLC, a registered investment advisor, or b) to another third party, including UMB Fund Services, Inc. and Foreside Fund Services, LLC, both SharesPost 100 Fund service providers.

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