Registration and Profile Information. When you sign up for an account, register to use our Site, or sign up for notifications or updates, we may ask you for your information, including your name, email address, phone number, photos, investment preferences, and net worth.

Communications. If you contact us directly, we may receive information about you. For example, when you email us, we will receive your name, email address and any additional information you choose to provide. If you subscribe to our newsletter, we will receive your name and email address.

Payment Information. When you make a payment to Xpressify, your credit card information, debit card information, billing information, and any other financial information necessary to complete your payment (“Payment Information”) is processed by our third-party payment processor (Stripe), and we do not collect, store, or process your Payment Information. For more information, please see the Payment Processing section below.

Careers. If you decide to apply for a job with us, you may submit your contact Personal Information and your resume online. We will collect the Personal Information you choose to provide us as part of your job application, such as your contact information, current employment information, and other Personal Information you choose to submit with your application and on your resume. If you apply for a job with us through a third-party platform, we will collect the information you make available to us through such third-party platforms.

Location Information. When you use our Site, we may infer your general location information. For example, your IP address may indicate your general geographic region.

Device Information. We receive information about the device and software you use to access our Site, including internet protocol (IP) address, web browser type, operating system version, and device identifiers.

Usage Information. To help us understand how you use our Site and to help us improve it, we automatically receive information about your interactions with our Site, such as the pages or other content you view and the times of your visit.

Your Contacts. We also collect your contacts if you invite them to use the Site or share information or content with them from Site.

Analytics Partners. We use analytics services such as Google Analytics and Matomo 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 about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Information from Cookies and Similar Technologies. We and our third-party partners may collect Personal Information using Cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer. They contain information that is transferred to your computer’s hard drive. We and our third-party partners may also use pixel tags and web beacons on our Site. These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Site. This aids your experience when you use our Site and allows us to improve the functionality of our Site. Cookies can be used for performance management (i.e., collecting information on how our Site are being used for analytics purposes). They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details. Below is an overview of the types of Cookies we and third parties may use to collect Personal Information.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept Cookies from the Site, you may not be able to utilize the features of the Site to its fullest potential.

When you make purchases through our Site, your payment is processed by a third-party payment processor such as Stripe (“Payment Processor”). This Payment Processor may collect Payment Information and other information from you, including your name, email address, and billing address. The use of your information by the Payment Processor is governed by its terms and conditions and privacy policy, and information we receive about you from our Payment Processor is governed by this Privacy Policy.

Information From Third-Party Services. If you choose to link our Services to a third-party account, such as Facebook or Google we may receive Personal Information about you, including your name, email address, profile information and your photo. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.

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.

We may use the information we collect:

If you are located in the European Economic Area or the United Kingdom, we only process your Personal Information when we have a valid “legal basis”, including as set forth below.

We do not share or otherwise disclose Personal Information we collect from you except as described below or otherwise disclosed to you at the time of the collection.

Partners and Affiliates. We may share Personal Information with our partners, corporate affiliates, parents, or subsidiaries for any purpose described in this Privacy Policy.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Site.

Marketing. We do not rent, sell, or share Personal Information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.

User Content. Our Site provides social services in which you can find, enjoy and share content. If you provide information regarding a project for potential investors, your name, user name, and other profile information will always be viewable and searchable by other users. The content you post to the Site will be displayed on the Site and viewable by other users by default. Although this content is public by default, below in the “Your Choices” section of this Privacy Policy, we describe the controls that you can use, along with other relevant settings associated with your account, to limit the sharing of certain information. We are not responsible for the other users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Site.

Analytics Partners. We use analytics services such as Google Analytics and Matomo 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 about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies on our Site and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/) or Digital Advertising Alliance (http://optout.aboutads.info/?c=2&lang=EN). 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.

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: (i) comply with law enforcement requests and legal process, such as a court order or subpoena; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may disclose and 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 business or assets.

Consent. We may also disclose information from or about you or your devices with your permission.

Sharing Preference. To change whether certain information is publicly viewable, you can adjust the settings in your account.

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

If you choose not to provide us with the information we collect, some features of our Site may not work as intended.

Your European Privacy Rights. If you are located in the EEA or the UK, you have additional rights described below.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies. You can block Cookies by setting your internet browser to block some or all Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies), you may not be able to access all or parts of our Site. By using our Site, you consent to our use of Cookies and our processing of Personal Information collected through such Cookies, in accordance with this Privacy Policy. You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Site using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Site may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

Our Site may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”). We are not responsible for the privacy practices of these Third-Party Services. 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-Party Services. If you have any questions about how these other sites use your Personal Information, you should contact them directly. We encourage you to read their privacy policies before providing any information to them.

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When we process Personal Information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Site, the impact on our Site we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal 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 Personal Information.

Our Site is hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use our Site from the EEA, the UK or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the U.S. for storage and processing. We may transfer your information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. Also, we may transfer your information from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Site. By providing any information, including Personal Information, on or to our Site, you consent to such transfer, storage, and processing.

We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and no parts of our Site are directed to children. If you learn that a child has provided us with Personal Information in violation of this Privacy Policy, please alert us privacy@xpressify.com.

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 Site, we will attempt to notify you through the Site, by email, or by other means.

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@xpressify.com or write to us at:

131 Dartmouth Street, 3rd Floor

Boston, MA

02116