Privacy Policy

Our Policy

This Privacy Policy describes the policies and procedures of Access Investors Network, Inc. (“Company”, “we” or “us”) with respect to the collection, use, dissemination, disclosure and protection of personal and other information about you received or generated by Company when you use or interact with the Access mobile application (together with any updated, modified, new and successor versions thereof, the “Access App”) or any associated services, applications, websites or social media channels (collectively, together with the Access App, the “Services”) offered or made available by Company.  By using or accessing the Access App or other Services or by submitting information to Company, you consent to this Privacy Policy.   This Privacy Policy applies to both individuals and entities who have signed up for or who access or use the Access App or other Services (any of the foregoing referred to herein as “you” and “your”). Users (“user” or “users” include the crowdfunding platforms that host the debt/equity or other similar information on the Access App and the investors (accredited or unaccredited) that seek to invest in such deals and opportunities.

Users (“user” or “users”) include:

·     Crowdfunding platforms that host the debt and equity investment deals and other related    information on the Access App;

·     Investors (accredited or unaccredited) that seek to invest in such deals and opportunities.

This is a non-exhaustive list and can be modified and/or supplemented in accordance with necessitated

changes.

Updates and Changes to Privacy Policy

This Privacy Policy is subject to updates and modification from time to time.  We will provide notice of any changes by posting the new Privacy Policy on our website located at http://www.accessinvest.com/privacy and/or the Access App or other publicly accessible portions of the Services. You are advised to consult this Privacy Policy regularly for any changes or updates.  Your use of the Access App or other Services after such update or modification constitutes your acceptance of such changes to this Privacy Policy. We are only responsible for placing notice of such changes or updates. It is your responsibility to regularly check for such changes or updates.

Terms of Service

This Privacy Policy and you are also subject to the Company’s Terms of Service (the “TOS”) and the applicable terms and conditions of the TOS (including but not limited to limitations on damages, jurisdiction of disputes and application of law) shall apply to this Privacy Policy and any disputes relating to privacy and use or protection of information hereunder. Refer to the TOS for full information on liability and all other related matters. This Privacy Policy alone does not provide all the necessary information with regards to use of the Access App and the legal devices that could be triggered. 

What Information Do We Collect?

We collect, receive, generate and store the following types of information:

•     Personal Identifying Information: Personal Identifying Information is information that can be used to identify or contact you, including but not limited to your name, physical address, email address, birthdate, telephone number, account identifiers, account password, payment information, credit card information and other billing data.  We may collect, receive and store Personal Identifying Information when you sign up or register on or with the Access App or other Services or when you fill out forms or questionnaires or complete your profile through the Services.  We may also obtain your Personal Identifying Information when you subscribe to email alerts, updates or newsletters or other special features through the Services or when you otherwise directly provide such information to us.

•     Personal Non-Identifying Data:  Personal Non-Identifying Data is information about you or your characteristics, activities or behavior which cannot be used to identify or contact you or which has been stripped of any Personal Identifying Information.  This type of information includes for example, and without limitation, an individual’s gender, city or state of residence, age, and non-identifying characteristics, as well as information about your investment experience, status as an accredited investor, nationality, employer restrictions on investments, preferences regarding deals of interest and asset classes, amounts of preferred investment, amounts of money available to invest and similar information.  We collect, receive and store Personal Non-Identifying Data when you directly provide it to us through the Access App or other Services (such as through sign-up, registration, forms, questionnaires, direct communications or similar mechanisms).

•        User Content:  User Content (“User Content”) is information, data, text, files, software, graphics, music, audio, photographs, video, messages, communications or other materials (other than Personal Identifying Information or Person Non-Identifying Data), that you upload, submit, post, transmit, share or otherwise provide on, through or to the Access App and other Services. For example, we receive and store User Content provided to Company when you:

(a) use the Services; and/or

(b) post, upload, submit or otherwise provide content, materials or other information on, through    

             or to the Services; and/or

(c) fill out surveys or questionnaires or sign up for or enter promotions, events or other special activities on, through or to the Services; and/or

(d) communicate with Company or with other users or participants of the Services (including the content of such communications and information provided in connection with such communications)

These are but a few examples as to how we obtain User Content. This is not an exhausted or exclusive list.

·     Information We Collect or Generate About You and/or the Use of Our Services: We may collect, generate and store certain types of information whenever you use the Access App or other Services or otherwise interact with us.  For example, we may generate analytics based on your preferences, characteristics, use and interactions with the Access App, including your selection of deals of interest.  Our Services may then analyze such data and generate derivative data or aggregated data as well as reports and other output.  As another example, we may automatically track or record your use of and activity on the Access App, the time and date of your activities, your device ID, IP address, browser type, Internet Service Provider, page views, domains, operating system and similar information.  Also, we may automatically send and receive information to and from a computer, mobile phone or other device in connection with the use of the Services. Like many websites and online services, we may also use "cookies" (see below), log files, web beacon technologies and other automated tools to obtain certain types of information when a web browser, mobile application or other application accesses our Services.

How Is Your Information Used?

 Company may use the information submitted, collected, received or generated from and/or about you for    

  any of the following purposes:

•     To operate, provide, administer, develop, and improve our Access App and other Services, and tooperate and support Company’s related businesses.

•     To curate and show you deals of interest through the Access App or other Services.

•     To provide your Personal Identifying Information, deals of interest and other information about you (including without limitation contact details and questionnaire or “know your customer” information) to crowdfunding platforms or other services offering investment opportunities for debt, equity and/or similar investments as well as deal sponsors and others associated with such deals of interest (collectively, “Crowdfunding Sources”), so that such Crowdfunding Sources may contact you with respect to such deals of interest and related matters and/or, if applicable, so that you can be signed up or open an account with such Crowdfunding Source. 

•     To provide Crowdfunding Sources and other outside sources information on investor preferences and the types of deals investors are interested in.

•     To better understand how users access and use our Access App and other Services on an aggregated and individualized basis, to track and monitor usage, to conduct quality control, to fix technical and other errors or problems, to conduct market research and to respond to user desires and preferences.

•     To analyze, compile, publish, sell and otherwise similarly commercialize information (other than Personal Identifying Information), including without limitation derivative information and analyses, relating to usage and users of the Services.  The foregoing includes, for example, the distribution or sale by Company of aggregate or de-identified Personal Non-Identifying Data or the use of Personal Non-Identifying Data to provide products or services to third parties.

•     For advertising, marketing and promotional purposes (excluding the provision to third parties of, or the publication of, any Personal Identifying Information).

•     To provide personalized experiences and recommendations, language and location customization, personalized help and instructions, or other responses to the usage of our Services.

•     To provide user support and handle inquiries.

•     To communicate with or contact users concerning the usage of or participation in the Services, and for other customer service; this could include use of e-mail addresses to send messages and notices for the purposes described above and below.

•     To offer content, services, or other products and services, including to develop new services and products.

•     To provide news and newsletters, special offers, promotions, and targeted advertising (which excludes the provision to third parties of, or the publication of, any Personal Identifying Information).

•     To comply with applicable laws, rules and regulations and any regulatory mandate or court order.

•     To enforce our TOS and other applicable agreements, rights and remedies.

•     To protect the safety of any person, to address fraud, security or technical issues, or to protect Company’s rights or property.

•     To use in any other manner, or for any other purpose, for which you have given express permission or consent to Company.

When is Information Shared with or Disclosed to Public or Other Third Parties?

Information provided by our users is an important part of our business.  Company will share and disclose information submitted, collected, received or generated from and/or about you only as compatible with the purposes described above, when we have permission or consent (as may be provided by you from time to time through the Access App, Services or otherwise), or as described in this section as follows:

•    Investment-Related Disclosures: Company may disclose your Personal Identifying Information, deals or transactions in which you have expressed an interest, you investor status and profile and other related information about you (including without limitation contact details and questionnaire or “know your customer” information) to Crowdfunding Sources so that such Crowdfunding Sources may contact you with respect to such deals or transactions of interest and related matters and/or, if applicable, so that you can be signed up or open an account with such Crowdfunding Source.  Company may also provide Crowdfunding Sources and other outside sources information on investor preferences and the types of deals investors are interested in.

•   Aggregated Data and Anonymous Data: Company may publish and otherwise disclose (a) on an    aggregated basis, information (including derivative information and analyses) relating to usage and users of the Services, and (b) information that does not contain Personal Identifying Information or is de-identified and not connected to the name of an individual or entity nor connected to similar information that would allow one to be specifically identified or contacted.

•   Disclosures In Connection with Permitted Uses:  Company may disclose your information (other than Personal Identifying Information) to third parties in connection with the purposes described in the previous section such as, for example, to commercialize non-identifying information relating to usage and users of the Services or to implement advertising, marketing or promotional activities or transactions. Company may also disclose the name of individuals and entities who have signed up for Services or otherwise contracted with Company in Company’s own marketing, advertising and promotional materials.

•    Company Affiliates: We may share any or all of your information with our subsidiaries and other affiliates, but only if those entities are either subject to this Privacy Policy or follow practices that are in accordance with this Privacy Policy and that are guided by this Privacy Policy. Such disclosure of User information to eligible subsidiaries/affiliates shall be protected to the full extent that this Privacy Policy will allow.

•   Public Forum: Any User Content or other user information, content or materials submitted, posted, shared, transmitted or otherwise provided to public portions of the Access App or public portions of other Services may be shared with the public without restriction.  [1]Company also reserves the right to publish or make publicly available any information that is already publicly available prior to the time first provided to or collected by Company or information that becomes publicly available without any action or omission on the part of Company.

•   Contractors, Collaborators and Agents: We may employ other companies, vendors, service providers and individuals to perform functions or services for Company or otherwise act on our behalf. Examples include resolving service problems, hosting websites or software, correcting errors related to the execution of the Services, sending postal mail and e-mail, analyzing data, providing marketing assistance (including data concerning marketing and promotional programs), developing websites and software, providing customer service, assisting Company with providing, administering, developing or improving the Services, and/or for other purposes within the ordinary course of business. These third parties may have access to the Personal Identifying Information and other information needed to perform their functions on our behalf.  We use reasonable efforts to require these companies to (1) provide adequate protections for Personal Identifying Information that are no less protective than those set out in this Privacy Policy and (2) use Personal Identifying Information only for the purposes for which the third party has been engaged by us. We are not liable for the acts or omissions of these third parties, except as provided by applicable law.

•   Business Transfers and Collaborations: As we continue to develop our business, we might sell the Company and/or its business or assets and/or sell or buy applications websites, services, subsidiaries, or other businesses; or we might collaborate or partner with other companies in strategic transactions, business arrangements or licenses. In such transactions, customer and user information and information regarding usage of the Services (including without limitation Personal Identifying Information and Personal Non-Identifying Data) generally would be one of the transferred business assets or otherwise one of the components of, or involved in, the transaction, we may therefore share this information in connection with such transactions or arrangements.

•   Compliance with Law and Protection of Company and Others: We reserve the right to disclose Personal Identifying Information and any other information when we believe release is appropriate to comply with the law, judicial proceeding, court order, subpoena or other legal process; detect, prevent, or otherwise address fraud, security, emergency situations or technical issues; enforce or apply our TOS and other agreements, rights and remedies; or protect the rights, property, or safety of Company, our employees and contractors, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.

The Services may include or interoperate with applications, services, features or functionalities provided by third parties. In connection with such third party applications, services, features or functionalities, you may send (or such third parties may get access to) certain information about or related to you or your activities therewith.  The use, storage and disclosure of such information by these third parties is subject to their own privacy policies and hence this Privacy Policy does not apply to them in this regard.

Security and Protection of Your Information

Company is very concerned with safeguarding your information and protecting the security of your Personal Identifying Information and Personal Non-Identifying Data.  We use appropriate, industry-typical security measures and technology to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, user information covered by this Privacy Policy.  In this regard, we employ administrative, physical and electronic measures designed to protect personal information from unauthorized access and disclosure and to safeguard such information against loss, theft, alteration and destruction.  No method of security is 100% secure. 

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored "personal data" (as defined in applicable statutes on security breach notification) to you via email or conspicuous posting on or through the Services in an expedient manner and without unreasonable delay, insofar as these are consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Third Party Breach

We will not be held liable for any 3rd party breach.  It is our obligation to prevent any 3rd party breach and to rectify any 3rd party breach if there is such a breach. The appropriate measures will be taken to ensure that a 3rd party breach does not occur.

Changing or Deleting Your Information

Company does not have a mechanism for you to directly review, edit or delete any of your information on or stored in the Access App or other Services or otherwise by Company, and information may be subject to any applicable record retention policies that we may have in place. If you would like us to delete your Personal Identifying Information in our system, please contact us and we will consider making good faith efforts to accommodate your request, though we have no obligation to do so (and will not do so if we have any legal obligation to retain the record or legitimate business need to retain such information). See below for privacy contact information.  In such cases, we ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests because of the reasons stated above or because such requests are unreasonably repetitive or systematic, require disproportionate technical effort, relate to information that is incorporated into other databases or Services as permitted by this Privacy Policy, jeopardize the privacy of others, or would be impractical (for instance, requests concerning information residing on backup tapes or derivative information that is not separable). Because of the way we maintain certain Services, after information is deleted, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Cookies and Other Files

Like many services, websites or applications, we may use "cookies" or similar technologies to collect information. A cookie is a small data file that we transfer to a computer's memory for record-keeping purposes. We may use cookies or such other technologies to improve the quality of the Services, including for storing user preferences and tracking user trends and for any of the other purposes permitted in this Privacy Policy.  We may utilize persistent cookies to save your registration/member ID and login password for future logins to the Services.  We may utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by Company users and web traffic routing on the Services. Unlike persistent cookies, session cookies are usually deleted from your computer when you log off from the Services and then close your browser. Third party advertisers on the Services may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or functionalities of the Services.

Log file information is automatically reported by your browser each time you access a web page. When you use the Services, our servers may record certain information that your web browser sends whenever you visit any website or utilize any other services or applications. These server logs may include information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other information.  When you use the Services, we may employ clear GIFs (also known as web beacons) or similar mechanisms, which are used to track the online usage patterns of our users anonymously.  We may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients.  In addition, we may employ similar tracking technologies for mobile devices to collect and store information with respect to the Access App.

International Transfer

Our Services are hosted in the United States.  If you use the Services from the European Union, Asia or any other country outside the United States with laws or regulations governing personal data collection, use and disclosure that differ from the United States laws and regulations, please be advised that through the continued use of the Services, you are transferring information to the United States and you consent to that transfer.  Your information may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us or use the Services, Company transfers personal information to the United States and processes it there, and your submission of such information represents your consent and agreement to that transfer.[2]

Our Policy Toward Children

In order to use our Access App and other Services you must represent and warrant that you are over the age of 18 in the sign-up process.  Children under the age of 18 are not eligible to use the Services and must not attempt to sign-up with the Services and/or submit any personal information to us.   We do not knowingly collect personal information from any person who is under the age of 18 or allow them to register. If it comes to our attention that we have collected personal data from a person under the age of 18, we will delete this information as quickly as possible.

Links to Other Access Apps, Services and Applications

Our Services may contain links to, interoperate with, and allow you to share content to and from third party services, websites and applications. The fact that we link to a website, service or application or allow you to share content through these third parties is not an endorsement, authorization or representation that we are affiliated with that third party, nor is it an endorsement of their privacy or information security policies or practices. Other websites, services and applications follow different rules regarding the collection, use, storage or disclosure of the personal and other information. We encourage you to read the privacy policies or statements of the other websites, services and applications you use. This is at your own discretion and it is not our obligation to enforce this on our users.

Limitation of Liability

Even though Company has taken reasonable commercial steps and efforts to prevent Personal Identifying Information and other information covered by this Privacy Policy from being accessed, used, intercepted, disseminated or disclosed by unauthorized individuals in violation of this Privacy Policy, you should know and you acknowledge that Company cannot fully eliminate security risks associated with your information.  You expressly acknowledge and agree that uploading, posting, providing, storing, using, analyzing, transmitting, sharing and/or allowing access to Personal Identifying Information and other information on, through, in or to the Services, and the use of all such Services, are all done at your sole risk and responsibility.   You expressly acknowledge that Company is not liable for (i) any special, indirect, consequential, incidental or punitive damages, costs, or liabilities whatsoever arising out of or resulting from your use of the Services, including from uploading, posting, providing, storing, using, analyzing, transmitting, sharing and/or allowing access to Personal Identifying Information and other information; or (ii) any loss, disclosure or use of your Personal Identifying Information or other information.

Contacting Access Investors Network, Inc.

If you have any questions or comments about this Privacy Policy, your choices with regards to our aggregator and use of your user information or any other aspect of the Site or Services, please contact us at contact@accessinvest.com.

Last modified: October 10, 2016