Important Disclosures

Privacy Policy

This Privacy Policy is incorporated by reference into the SharesPost User Agreement (the “User Agreement”). The term “SharesPost,” “we,” and “us” includes SharesPost, Inc., and its parents, successors, affiliates and subsidiaries. The Privacy Policy explains how we may collect, use, and disclose your information we obtain through the “Service” as defined in the User Agreement. This Privacy Policy also explains information on the choices your have with your data.

THE SERVICE COLLECTS YOUR INFORMATION

We collect the following information from you:

  • First, middle, and last name, including suffixes (Sr. Jr, PhD., etc.) if any;
  • address(es), email address(es) and phone number(s);
  • date of birth and age;
  • social security number, taxpayer number, and driver’s license number;
  • gender/sex, height, and weight;
  • financial net worth, holdings, transactions, statements, confirmations, banking information, and investment objectives;
  • occupation, employer, and income;
  • citizenship and residency status; and
  • cookies and usage data.

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.

DURING ACCOUNT REGISTRATION AND MANAGEMENT

You will 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 will 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

We may collect information on how the Service is access and used (“usage data”). Usage data may include information such as your computer’s Internet Protocol address (“IP address”), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We also collect information, such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Service. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. 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;
  • satisfy legal and regulatory requirements;
  • validate the information you provide to use;
  • detect, prevent, and address technical issues; 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 mail to the address, 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.

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.

AGGREGATE DATA

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

SHARESPOST MAY DISCLOSE YOUR INFORMATION

We will 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 will 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. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

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.

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 will 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.

EUROPEAN UNION’S GDPR RIGHTS

Residents of the European Union have rights afforded to them by The General Data Protection Regulation (“GDPR”). These rights include:

  • The right to be informed – To understand how the personal data you provide to us is used.
  • The right to access – To a copy of your personal data that we have and use.
  • The right to rectification – To correct any inaccurate or incomplete personal data.
  • The right to erasure – To erasure your personal data, when there is no compelling reason for us to continue to have it.
  • The right to restrict processing – To restrict the use of your personal data, when there is not compelling reason for use to continue to use it.
  • The right to data portability – To have your personal data available to you in a machine-readable, transportable format.
  • The right to object – To object to direct marketing.
  • Rights related to automated decision and profiling – To have decisions made by a human.

For more information about your rights under GDPR, or for a copy of the Record of Processing Activities, please reach out to us through the contact information provided at the bottom of the page. We will not charge you for you exercising your rights under GDPR.

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 are 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 U.S. Securities and Exchange Commission, we may need to keep information for three (3) to six (6) 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 privacy@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.

CHILDREN POLICY

Our Service does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

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 privacy@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.

FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act of 2018 (“CCPA”), grants, commencing on January 1, 2020, a California resident (“Consumer”) various rights with regard to personal information relating to that Consumer that is held by a business, including the right to request a business to delete any personal information about the Consumer collected by the business, and requires the business to comply with a verifiable Consumer request to that effect.

The categories of personal information collected by SharesPost and the purposes for which SharesPost uses that personal information are identified on page one of this Privacy Policy.

The act requires a business that collects personal information about a Consumer to disclose the Consumer’s right to delete personal information on its Internet Web site or in its online privacy policy or policies.

A Consumer will have the right to request that SharesPost disclose to that Consumer the categories and specific pieces of personal information the registered SharesPost entity has collected. Such disclosure must be made only upon the receipt of a verifiable Consumer request.

A Consumer shall have the right to request that SharesPost delete any personal information about the Consumer which SharesPost has collected from the Consumer. Upon receipt of a verifiable Consumer request from a consumer to delete the Consumer’s personal information, SharesPost shall delete the Consumer’s personal information from its records and direct any service providers to delete the Consumer’s personal information from their records, unless otherwise restricted by applicable law.

A Consumer shall have the right to request that a business that collects personal information about the Consumer disclose to the Consumer the following:

  1. The categories of personal information it has collected about that Consumer.
  2. The categories of sources from which the personal information is collected.
  3. The business or commercial purpose for collecting or selling personal information.
  4. The categories of third parties with whom the business shares personal information.
  5. The specific pieces of personal information it has collected about that Consumer.

Exercise of these rights can be requested through the phone number or email address below. That contact information is also found on the SharesPost webpage, www.sharespost.com. When exercising rights by the phone number below, please inform the SharesPost representative that the call relates to the Privacy Policy to ensure proper handling of the request(s).

CONTACT INFORMATION

SharesPost, Inc.
555 Montgomery St, Suite 1400
San Francisco, CA 94111
1-646-838-4505
privacy@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.