Online Privacy Statement
Last updated as of June 30, 2017
This Privacy Statement covers the following affiliated companies: WealthForge Holdings, Inc.; WealthForge Technologies, LLC; FundRoom, LLC; and WealthForge Securities, LLC. These entities are collectively referred to us the “Company”, “we” or “us”. We do not disclose information to non-affiliated companies except as described below.
Acknowledgment and Acceptance of Terms
The Company is committed to protecting your privacy. This Privacy Statement sets forth our current privacy practices with regard to the information we collect when you or your computer or mobile device interacts with our website. By accessing this website (“the Site”), you agree with and consent to the terms of this Privacy Statement.
Participating Third-Party Policies
This Site may contain links to other websites, or you may have been linked to this Site from another website, but this Online Privacy Statement does not apply to them and we are not responsible for their content. If you visit external websites, we recommend that you review their privacy policies. If we materially change our privacy policies or practices, we will also amend this Online Privacy Statement to reflect such changes. You should review the Privacy Statement each time you visit this Site.
Information We Collect and How We Use It
Collection of Personal and Technical Information
This Site will collect personal information that you provide. Providing this personal information represents your consent to the Company’s collection and use of such information in accordance with the Privacy Statement.
As further set forth below, this Site may also collect information about your computer and operating systems, such as your Internet Protocol address, domain name and system configurations and settings.
Additionally, if you access a password protected portion of this Site, then (a) once you submit your password, this Site will recognize you and will collect all information that you submit, including all electronic instructions (such as transaction information), and (b) any information collected about you from this Site may be associated with other identifying information that we have about you.
What anonymous data is collected through this Site?
The Company collects this information in five ways: directly from our web server logs, by recording web sessions, from the user, with cookies, and with web beacons or GIF files.
A. Web Server Logs:
When you visit our Site, we may track information to administer the site and analyze its usage.
Examples of information we may track include:
- - Your Internet Protocol address.
- - The kind of browser or computer you use.
- - Number of links you click within the site.
- - State or country from which you accessed the site.
- - Date and time of your visit.
- - Name of your Internet service provider.
- - Web page that linked you to our site.
- - Pages you viewed on the site.
B. Web Session Recording:
The Company may use a third-party vendor to record your web sessions on the Site. The Company, through this service, may records all your actions on the Site. However, Personal information that you provide via the Site is not recorded and is not provided to the third-party vendor providing the recording service or to any third party unrelated to the products and services for which you are accessing the site. Use of your personal information is discussed in Section 4.
One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. This simplifies the process of delivering relevant content and eases site navigation by saving your preferences and login information as well as providing personalized functionality.
The Company may collect, use, and share aggregated data, but does not allow other companies to place cookies on our Site except to enhance or enable full use of the site (such as merging into platform.wealthforge.com a site that relies on third-party cookies). You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. Most Web browsers can be set to notify you when an HTML cookie is placed on your computer. You can manually delete HTML cookies and set most browsers to refuse to accept HTML cookies, although doing so may affect your website experience. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web. Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. The IAB website at http://www.allaboutcookies.org/ tells you how to remove cookies from your browser. Further details are provided below about our cookie usage. Flash cookies may be removed by managing your Adobe® Flash® Player settings. To delete or prevent placement of Flash cookies, you will need to visit the Adobe® Flash® Player Help site at http://www.adobe.com/go/settingsmanager, click on the hyperlink for "Website Privacy Settings Panel" on the left side of the screen and follow the instructions for preventing third-party Flash content from storing data on your computer.
If you reject cookies by changing your browser settings then be aware that this may disable some of the functionality on our Site.
D. Personal Information from Users:
For some types of transactions or registrations, we will ask for information such as your name, address, email, telephone number or facsimile number, bank account number, and other information relevant to your request for participation in a transaction. You may also be asked to disclose personal information to us so that we can provide assistance and information to you. For example, we may need such information in order to provide online technical support and troubleshooting. We will not disclose personally identifiable information we collect from you to non-affiliated parties without your permission except to the extent necessary to provide the products and services, as described below.
The below is a Customer Identification Program Notice from WealthForge Securities, LLC relating specifically to investments in a WealthForge Securities, LLC offering.
Important Information about Making an Investment through WealthForge Securities, LLC; a member of FINRA/SIPC that does not maintain customer accounts, hold customer securities, or hold customer funds:
To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify, and record information that identifies each person who participates in an offering administered by a registered broker dealer. WealthForge Securities, LLC will collect the required information for each investor that chooses to participate in an offering through WealthForge Securities, LLC.
What this means for you: When you choose to invest in an offering administered by WealthForge Securities, LLC, we will ask for your full name, physical address, date of birth and other information that will allow us to uniquely identify you. We may also ask for a photocopy of a government issued identification, or that you provide other identifying documents.
E. Use of Web Beacons or GIF files:
The Company web pages may contain electronic images known as web beacons - sometimes also called single-pixel gifs - that allow The Company to count users who have visited those pages and to deliver co-branded services. The Company may include web beacons in promotional email messages or newsletters in order to determine whether messages have been opened and acted upon.
Some of these web beacons may be placed by third party service providers to help determine the effectiveness of our advertising campaigns or email communications. These web beacons may be used by these service providers to place a persistent cookie on your computer. This allows the service provider to recognize your computer each time you visit certain pages or emails and compile anonymous information in relation to those page views, which in turn enables us and our service providers to learn which advertisements and emails bring you to our website and how you use the site. The Company prohibits web beacons from being used to collect or access your personal information.
How We Use, Share and Disclose Personal Information That We Collect via This Site
Personal information you provide and the personalized data you create and save on the website and the registration and investment flow pages are used to provide services to you and to inform you of products, services or opportunities that may be available through the Company. Information and data you provide will also be used to administer our business, the Site and our products and services in a manner consistent with this Privacy Statement, the terms and conditions that govern your use of this Site and all applicable laws, rules, regulations or other legal obligations. If you provide us with your name, address, telephone number and/or email address, or have done so in the past, the Company may contact you by telephone, mail and/or email. You may change your contact details or unsubscribe from mailing lists at any time by contacting us as provided below. Email or other electronic communications sent to us through this Site will be maintained in a manner consistent with our legal and regulatory requirements regarding member, client and public communications.
We do not rent, sell or share your personal information or personalized data to unaffiliated organizations except to provide products or services you have requested, when we have your permission or under certain limited circumstances. For example, we provide such information to companies who work on behalf of or with the Company, subject to confidentiality agreements. These companies may use your personal information to help the Company communicate with you about the Company’s services and services or to assist the Company in the provision of its products and services.
Information provided by you may also be shared with the issuer of the offering in which you have expressed an interest, WealthForge Securities, LLC (and its independent registered representatives) providing services for that issuer, as well as other companies providing services in connection with the offering, such as: escrow agents and banks, credential-checking services, and the issuer’s special purpose vehicle(s) for that offering. In each case, disclosure is subject to applicable privacy law and is limited to the extent the third party needs the information.
Specifically, social security numbers are only shared with WealthForge Securities, LLC and its personnel processing the transaction for the issuer, and third-party service providers to WealthForge Securities, LLC that use social security numbers for the limited purpose of providing services for the offering and that have agreed to maintain the confidentiality of your information.
The collection, further use, or disclosure of your information by issuers, unaffiliated service providers or by other third parties is not the responsibility of the Company. Such collection, use, or disclosure is governed by the third parties’ privacy policies.
Changes to this Statement
The Company has the discretion to update this Privacy Statement at any time. When we do, we will also revise the "updated" date at the top of this page. We encourage you to review this Privacy Statement each time you access this site to stay informed about our use of your information. Access or use of the site is subject to the current version of the Privacy Statement.
Notice to Residents of California and Nevada
A. California Residents
California law requires that we obtain your affirmative consent before we share your nonpublic personal information with non-affiliated third party companies.
Information provided by you in the registration and investment flow pages may also be shared with the issuer of the offering in which you have expressed an interest, WealthForge Securities, LLC (and its independent registered representatives) providing services for that issuer, as well as other companies providing services in connection with the offering, such as, escrow agents and banks, credential-checking services, and the issuer’s special purpose vehicle(s) for that offering. In each case, disclosure is subject to applicable privacy law and is limited to the extent the third party needs the information.
Specifically, social security numbers are only shared with WealthForge Securities, LLC (and its independent registered representatives) processing the transaction for the issuer, and third-party service providers to WealthForge Securities, LLC that use social security numbers for the limited purpose of providing services in connection with the offering and that have agreed to maintain the confidentiality of your information.
In addition, if you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by the Company to its affiliates and/or third parties for their direct marketing purposes.
To make such a request, please send an email with your first name, last name, mailing address, email address and telephone number to email@example.com. Please include "California Privacy Rights" in the Subject line of your email.
You may also make such a request by writing to us at the address set forth in the Contacting Us section.
B. Nevada Residents
Nevada law requires us to disclose that you may elect to be placed on our internal do-not-call list by calling us at 804-308-0431. For further information, contact the Nevada Attorney General's office at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; by phone at 702-486-3132; or by email at BCPINFO@ag.state.nv.us.
How we Maintain the Confidentiality and Security of the Personal Information That We Collect via this Site
The Company maintains reasonable physical, electronic and procedural safeguards that comply with applicable laws and regulations to protect personal information about you, and works with vendors and partners to protect the security and privacy of user information. The Company maintains the information collected on servers located within the United States and does not transfer your data to other countries.
If you have questions regarding our Privacy Statement, its implementation, failure to adhere to this Privacy Statement and/or our general practices, please contact us at: firstname.lastname@example.org or send your comments to:
WealthForge Holdings, Inc.
Attention: Privacy Statement Personnel
6800 Paragon Place, Suite 237
Richmond, VA 23230