Privacy Policy

Updated: 1/28/2014

EarlyShares.com, Inc., together with its directors, employees, agents, suppliers, partners, and content providers (individually and collectively, "we," "us," “our,” or “EarlyShares”), a Delaware corporation, is committed to protecting your personal and financial information. This Privacy Policy (“Policy”) answers some questions about your nonpublic personally identifiable information and non-personally identifiable information we collect in connection with your use of www.EarlyShares.com (“Website”) and related services (“Services”), how the information will be used, what we do with it, how we protect it, and your correction or deletion of that information. As of the date listed above, we have made some changes to this Policy that may affect what information we collect about you from either you or from third parties, and with whom that information may be shared. Specifically, certain information we collect about you from third parties concerning your accredited investor status may be shared with certain other third parties in accordance with this Policy.

This Policy together with the General Terms and Conditions of Use (“Terms”) (collectively, the “Agreement”) constitutes a contract between you and EarlyShares and governs your use of the Website and/or Services and set forth the terms and conditions between you and EarlyShares when you access or use the Website or in connection with the Services, including participation or browsing. If you breach any of the terms of the Agreement, your right to use the Website or right to use Services will terminate immediately. The Agreement does not apply to the practices of companies that EarlyShares does not own or control or to individuals whom EarlyShares does not employ or manage. EarlyShares reserves the right to use and control the information collected on the Website. By using the Website, you acknowledge that you have read and understood the Agreement and consent to the practices described in the Agreement.

In the course of providing financial products and services, we need to collect and maintain certain nonpublic personally identifiable information about you. We may use this personal information about you to service and maintain your account, process transactions in your account, facilitate communication between you and other users, respond to inquiries from you or your representative, develop, offer, and deliver products and services, or to fulfill legal and regulatory requirements. When you visit our Website, we may collect technical and navigational information, such as computer browser type, Internet protocol address (“IP address”), pages visited, general statistical and tracking information, your computer operating system and browser information, and average time spent on our Websites. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Web design and functionality. We train our employees about privacy and limit access to this information. To maintain security of your online session and prevent unauthorized users from accessing your account we use firewall barriers, encryption techniques and authentication procedures.

We will not sell, rent, license, or disclose any of your nonpublic personally identifiable information to any nonaffiliated third parties, except as described below. If you decide to close your account, EarlyShares will continue to adhere to the privacy policies and practices as described in this notice.

We collect information about our users in four ways: directly from the user, from our web server logs, through cookies, and from third parties with whom we may contracts with to perform certain functions or services on our behalf.

Information Collected Through Users

Any personal information or content that you voluntarily disclose for posting on the Website (“User Content”) becomes available to the public. You can view and modify this information within the self-maintenance area of the Website. If you remove User Content, copies may remain viewable in cached and archived pages or if other users have copied or stored your User Content. We reserve the right, but have no obligation, to monitor the User Content you post on the site. We have the right to remove any information or material posted on the Website for any reason or no reason, including without limitation, if in our sole opinion, such information or material violates, or may violate, any applicable law, the Agreement, or to protect or defend our rights or property or those of any third party. We also reserve the right to remove information upon the request of any third party.

The following information may be collected in connection with your use of the Website and Services:

  1. Information you provide online and on applications or other forms, or through discussions we have with you or your representatives, such as your name, address, e-mail address, telephone number, Social Security number, date of birth, income, employment information, investment experience, and any information about your personal goals or objectives.
  2. Information entered online that may be stored even if you do not complete or submit an application;
  3. Information about your transactions with or through us, such as your account balance and account history, if applicable;
  4. Information from third parties in order to verify your identity, investor status, or to prevent fraud;
  5. Information from third parties that you authorize to provide information to us;
  6. Information about you from consumer-reporting agencies, such as your credit scores; and
  7. Information you provide to us about your external financial accounts in order for us to provide you special product and service features.
  8. Information regarding external financial accounts will not be disclosed to any other entities.

E-mail

If you correspond with us by e-mail, we may retain the content of your e-mail messages, your e-mail address and our responses in our e-mail records. We will retain e-mails that are sent from EarlyShares to you. Emails are subject to archival, monitoring or review by and/or disclosure to, someone other than the recipient. We retain e-mail correspondence to build records of our relationship and to measure and improve our service. We may, over time, delete these records if permitted by law.

You may receive periodic updates emails from EarlyShares. You may opt-out of the emails at any time. Instructions for unsubscribing are included in each email.

Cookies

Cookies are small text files, which often include a unique but anonymous code, sent by a Website server to your Web browser and stored on your computer. They recognize you as a repeat visitor, allowing you to log in faster and enhance your navigation through the site. Cookies do not identify you by name as an individual or by account number. Cookies also track traffic patterns on our website, helping us understand how you are using our Website. This information allows us to improve the security, content, navigation and functionality of our Website. Cookies note that your browser was used to visit certain sites, pages, or advertisements on a certain date, but are not used to collect or disseminate any personal information.

Additionally, we use cookies on our Websites and the sites on which we advertise to track advertising performance and to collect aggregate data on Web page viewing. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

You can manually disable cookies. You should review the online documentation of your browser or consult with the provider of your browser for instructions on how to disable cookies. However, disabling cookies may cause some parts of the Website to not function properly.

Internet Protocol (IP) Address

As you enter our Website, we capture and retain the IP address of the device you are using, such as a personal computer or a handheld device. The IP address does not identify you or your personal information and is used for security purposes only. We may use this information to monitor and prevent fraud, diagnose problems, and (anonymously) estimate demographic information.

Nonpublic Personally Identifiable Information

In the event that you request access to the confidential investment details and business details of an offering on EarlyShares.com, the email address linked to your EarlyShares user account will be furnished to the business owner of the issuer company to facilitate communication between you.

EarlyShares does not sell, rent, or license, or otherwise disclose nonpublic personally identifiable information about current or former clients to anyone, except in cooperation with the government and regulatory agencies with a lawful summons, court order, subpoena, fraud investigation, audit or regulatory examination, investigations of a violation of legal rights of EarlyShares or any other person, or as permitted or required by law, to non-affiliated third parties that help us provide services to you. For example, the United States Securities and Exchange Commission (“SEC”) requires that we verify your accredited investor status before you may invest in any offerings made available through our Website. Toward that end, EarlyShares employs or contracts with other third parties, companies (e.g., Veri-Tax), 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, accreditation/financial/credit verification, electronic document signing, payment storing and processing, sending postal mail and e-mail, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to nonpublic personally identifiable information concerning you that they provide to us. In turn, in order to comply with SEC requirements, we may have to share such information with issuers of securities or other offerings made available on our Website, with broker dealers, or with the National Securities Corporation depending on the types of investments you will be making through the Website.

All non-affiliated third parties that accept or receive this information from us are obligated contractually or by law or regulation to keep this information confidential and to use the information only to provide the services we ask them to perform. These non-affiliated third parties will be provided with only that information necessary to perform their functions on our behalf, and we will not allow them to use your personally identifiable information for any other purpose. EarlyShares shall be entitled to transfer to a third party information it maintains, including any personally identifiable information, in connection with a transaction or proceeding involving a transfer of some or all of the assets relating to the Website or a business in connection with which such information is maintained.

We may store nonpublic personally identifiable information in locations outside of our direct control such as on servers, or databases co-located with hosting providers. You may decline to submit nonpublic personally identifiable information through EarlyShares, in which case we may not be able to provide certain services to you. You may update or correct your account information and email preferences at any time in your online profile.

EarlyShares may buy or sell assets or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution. In any such transfer of information, your user information would remain subject to the Agreement.

Protecting Your Information

EarlyShares uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We employ a variety of security measures, including encryption and authentication tools. Your personal information is stored behind firewalls and is only accessible by a limited number of people who are required to keep the information confidential.

If you have a unique password or personal identification number (“PIN”) for access to non-public areas of the Website, you are solely responsible for all activities that occur in connection with your PIN. Accordingly, you should take steps to protect the confidentiality of your PIN. Notify EarlyShares immediately if you become aware of any disclosure, loss, theft or unauthorized use of your PIN. To protect your privacy and security, maintain the secrecy of your unique password or PIN and account information, and for controlling access to your email communications from EarlyShares, at all times.

Despite these measures, we cannot guarantee that unauthorized persons will always be unable to defeat our security measures.

Compromise of Personal Information

In the event that personal information is compromised as a result of a breach of security, EarlyShares will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in the Agreement, or as otherwise required by applicable law.

Children's Privacy

This Website is intended to be used by adults. It is not intended for children. EarlyShares does not knowingly collect or solicit personal information from anyone under the age of thirteen (13) or knowingly allow such persons to register. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 is allowed to provide any personal information to EarlyShares. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at [email protected].

Third Party Websites

When you select a link to a third-party site, you are subject to the privacy and security policies of the third party and EarlyShares’ Policy is no longer in effect. EarlyShares does not control the privacy policies or the privacy practices of any third parties. We are not responsible for the practices employed by Websites linked to or from our Website nor the information or content contained therein. Your browsing and interaction on any other Website, including those that have a link on our Website, is subject to that Website's own rules and policies. Please read over those rules and policies before proceeding.

Notification Procedures

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on our Website page, as determined by EarlyShares in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in the Agreement.

Changes to this Privacy Policy

EarlyShares reserves the right to make changes to the contents of the Policy at its’ discretion. Any changes or updates become effective immediately upon posting to this site. Changes to the Policy will be reflected at the top of this Web page with a posting of a “last updated” date. Please be sure to check this page periodically for changes. You are bound by changes to the Policy when you use the site after those changes have been posted.

By using the Website, you consent to the Agreement. If you do not agree with some, or all of the terms of the Agreement, you may not visit our Website or use the Services.

If you have questions about the Privacy Policy or would like to suggest improvements, please contact us at [email protected]; or mail us at 1200 Brickell Avenue, Suite 510, Miami, Florida 33131.