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Welcome to VENTURE.co! By accessing the VENTURE.co Platform or the VENTURE.co website, www.venture.co (the “Website”) you (“you”) are agreeing to the terms in this Privacy Policy. If you do not agree with the terms in this Privacy Policy, you should stop using the Platform and/or the Website.

 

As explained below, VENTURE.co collects information from users (“User”) in various ways when you interact with our Platform. By using our Platform, you consent to our collection and use of information as explained in this Privacy Policy. Please note that if you choose to access or invest in any product made available to you, such offer may be subject to separate terms, including but not limited to, new or additional privacy notices, or policies, or Terms.

 

Collection of Personal Information

VENTURE.co collects personal information from you (“Personally Identifiable Information” or “PII”) when you use the Platform, including, but not limited to, registering a user account, sending an email through the Platform, makingor managingan investment through the Platform. Personally Identifiable Information refers to non-public information that personally relates to or identifies you, such as your name, password, age and date of birth, email address, postal mailing address, home/mobile telephone number, Social Security number and/or taxpayer identification number, Internet protocol (“IP”) address, assets and income, and other similar information, or other information you provide or upload to the Platform such as identity documents, answers to questionnaires, or responses filled in on blank forms by you made available on the Platform. We request that you provide VENTURE.co with personal information, including, but not limited to, your demographic information, employment information, financial information, suitability, and other information requested from time to time in the performance of fullfilling our service to you and to our Clients.

 

Collection of Other Information

VENTURE.co collects non-personally identifiable information from you regarding your usage of our Platform and the Website (“NonPersonally Identifiable Information” or “NPII”). Non-Personally Identifiable Information may include, without limitation, organization name, investment offering type, asset class and target amounts, pages viewed, browser type, operating system, internet connection speed, time spent viewing pages of our Platform or Website or using certain features of our Platform, demographic data such as server locations, clickstream data, location services, documents and videos viewed, cookies existing on your computer, and date and time and frequency of access or visits to our Platform or Website and other information which does not specifically identify you. For the Website, VENTURE.co collects this information using various technologies (some of which are described below), including, but not limited to, cookies, web session variables, and server log files. “Cookies” are pieces of information that may be placed on your computer by a service for the purpose of facilitating and enhancing your communication and interaction with that service. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.

 

Use of Information

VENTURE.co will use information you provide consistent with this Privacy Policy. VENTURE.co will use PII you provide to VENTURE.co to better serve you and enhance your experience with the Platform. VENTURE.co does not share or sell your PII with advertisers or other third parties, except only for the purpose of providing the Platform or Services as described in the User Terms available at VENTURE.co Legal (https://venture.co/legal), enhancing the Platform or Services to you, preventing or addressing service or technical problems, at a User’s request in connection with customer support matters, or as may be required by law. VENTURE.co may use NPII, anonymized and in aggregate, to communicate about the Platform and its use.

 

Marketing. We may give some Users the option to use our Platform free of charge. These free services are made possible by the fact that organizational users order Plans and Services. If you register for our Platform as an Origination Party User, an Intermediary User, or an Affiliate, we will, from time to time, send you information about upgrades or in connection with your use of the Platform or Services, when applicable. Users who receive these marketing materials can opt out at any time subject to the Opt-out Policy below.

 

Other users. Our Platform is designed to help you collaborate with others to facilitate securities transactions and manage investments. If you register as a User with an email address on a domain owned by your employer or organization, or collaborate with other VENTURE.co users, collaborators and potential collaborators may see some of your basic information, like your name, employer name, and email address, or you may authorize the use of your PII with such collaborators. This helps you collaborate with other Users in connection with the Platform and Services and helps other Users share information with you. You control the information you share with other Users in the Platform. VENTURE.co may read, collect and analyze information transmitted between users for regulatory compliance and marketing purposes.

 

Data and Security

VENTURE.co uses reasonable security measures that are designed to protect PII from accidental loss, disclosure, misuse, and destruction. These measures include regular review of our data collection and storage process, ensuring that the data is encrypted and that we have up-to-date security software on our networks and servers. Wherever appropriate, VENTURE.co will obfuscate and/or encrypt information in our systems and/or during information transfer. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to log off when finished using a shared computer. Please be aware, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any information that you provide to us. You transmit information to us at your own risk.

 

VENTURE.co may use both NPII and PII that you provide: (1) to provide and enhance services and products requested by you; (2) to enable our vendors and contractors to provide and assist VENTURE.co in the operation, troubleshooting and analysis of our Platform and our Website; (3) to deliver email messages like e-signature notifications and document download links; (4) to verify your information; (5) for our Clients to comply with and meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations; (6) to protect our Platform and Services or its Users; (7) to engage in any other lawful activities VENTURE.co believe are consistent with the foregoing; and (8) when required by law or to protect against legal liability.

 

You may make your information, including PII, available to other Users of Platform and Services. As such, other Users may be able to personally identify you based on your information made available to them. VENTURE.co may employ or contract other third parties, companies, or individuals to perform certain functions or services on behalf of its Clients. Examples of these services from such third parties, companies, or individuals, may include ID 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 your information, including Personally Identifiable Information, needed to perform their functions or services, and may not use it for other purposes. VENTURE.co may also use and disclose Personally Identifiable Information and Non-Personally Identifiable Information to help VENTURE.co, or other Users carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business; to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Platform or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of VENTURE.co or Client business or assets. Any successor in interest to our business would acquire the information VENTURE.co maintains, including PII, and may alter the terms of this Privacy Policy.

 

Opt-out Policy

VENTURE.co may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional e-mails from VENTURE.co, you may unsubscribe completely by clicking the ‘unsubscribe’ link in the corresponding emails. VENTURE.co may also send you e-mail communications in connection with your use of the Platform (“Platform Communication”.) To unsubscribe from Platform Communications contact VENTURE.co Support at support@venture.co. Please note that opt-out requests may take up to forty eight (48) hours to process if such request does not adversely affect other users. If an opt-out request is made by User that is actively involved in any investments, such request will be processed in a case-by-case basis to ensure other users are not adversely affected. Please also note that at times VENTURE.co may need to send you Platform Communications with email that are transactional in nature such as electronic signature requests which are communications you will not be able to opt-out of. You will be able to modify the information concerning your account by visiting your profile page and editing any information you wish to change. You will be able to view and change your e-mail address, password, financial information, contact information, or other login information by visiting your account’s settings page. If you wish to delete your account or need help modifying account information, please contact VENTURE.co during posted service hours. VENTURE.co will require up to forty-eight (48) hours to process such requests. VENTURE.co reserves the right to retain certain NPII or PII as required by law or to protect against legal liability.

 

Children’s Privacy Policy

The Platform are not intended for use by minors. No one under eighteen (18) years of age is allowed to use the Platform, provide any personal information or receive our email distributions. Changes to This Privacy Policy VENTURE.co reserves the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to our Platform. You should review this Privacy Policy regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our Platform following the posting of any changes to this Privacy Policy means you accept such changes. Applicable Law and Jurisdiction The Platform and Services are maintained in the United States of America. By accessing the Platform or using any Services, you consent to and authorize the export of PII to the United States of America and its storage and use as specified in this Privacy Policy. This Privacy Policy shall be governed by, construed and entered in accordance with the laws of the State of New York applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard in the State of New York. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

 

Effective Date

This Privacy Policy was last updated on May 11, 2023

Privacy Policy

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