Effective date: November 1, 2021

Yield Crowd Foundation (Platform, we, our, or us) is committed to protecting the privacy of our users, and we strive to provide a safe and secure user experience. This Privacy Policy (Policy) describes how we use and share the information we collect through the Platform.

Platform includes the website at app.yieldcrowd.com, other websites and applications owned and operated by the Platform (including their content, tools, features, and functionality), and related services.

This Privacy Policy does not apply to websites, mobile applications or services operated by third parties, including affiliates of us, or when we act as a service provider or processor for a third party. Please refer to the privacy policies for those other websites and mobile applications for the data collection, use, and sharing practices applicable to those websites and mobile applications.

This Privacy Policy includes the following sections. You can jump to particular topics by clicking the headings below:

COLLECTION AND USE OF PERSONAL INFORMATION

Personal Information

Personal information means anything that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. We collect the following types of personal information.

Account Information

We collect your name and contact information, such as email address, mailing and physical address, phone or mobile number, zip code, date of birth, information about your spouse, location data, photographs, videos, comments, passport or driver’s license numbers, national/tax identification numbers, number and country of issuance of other government-issued documents, and other identification verification when you create an account. We also collect information relating to the actions that you perform while logged into your account.

We have a legitimate interest in providing account related functionalities to our users, including creating, maintaining, and securing your account. We also use this information to perform our contract to provide services to you. In some circumstances, we also collect this information to comply with laws, including “know your customer” laws.

Commercial Information

We collect information such as your trading experience, transaction history, details of investing trusts or entities that you are the contact point for.

We have a legitimate interest in confirming your status as a qualified purchaser, qualified client or for understanding other suitability requirements. In some circumstances, we also collect this information to comply with laws, including “know your customer” laws. We also have a legitimate interest in improving our risk mitigation systems to make sure we meet your needs by ensuring the services we provide are suitable for your circumstances.

Cookies and first party tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our "How We Collect Information" section for more information.

We have a legitimate interest in making our website operate efficiently or we rely on your consent for non-essential cookies, as applicable.

Cookies and Third Party Tracking

We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our "How We Collect Information" section for more information.

We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics, or we rely on your consent, as applicable.

Demographic Information

We collect personal information, such as your age or location.

We have a legitimate interest in conducting and further developing our business, for example, by understanding and analyzing our target demographics.

Distance Information

When you use one of our Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and your distance from a store that sells our products.

We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent to provide us with geo location information.

Email Interconnectivity

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

We have a legitimate interest in understanding how you interact with our communications to you.

Feedback/Support

If you provide us feedback or contact us for support we will collect your name and e-mail address, as well as any other content that you send to us, in order to reply.

We have a legitimate interest in improving the Platform.

Mailing List

When you sign up for one of our mailing lists we collect your email address or postal address.

We also have a legitimate interest in sharing information about our products or services.

Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores.

We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

Partner Promotion

We collect information that you provide as part of a co-branded promotion with another company.

We have a legitimate interest in fulfilling our promotions.

Surveys

When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

We have a legitimate interest in providing you with the opportunity to give us feedback about the Platform in the form of a survey (to the extent your jurisdiction does not require us to obtain prior consent).

Sweepstakes or Contests

When you participate in a sweepstakes or contest we collect information about you which includes contact information to notify you if you are selected.

We have a legitimate interest in operating the sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.

Website Interactions

We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.

We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

Web Logs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

What happens if a financial crime risk is detected?

We take financial crime seriously. If we, or a fraud prevention agency, believe that someone poses a financial crime risk then we may refuse to provide the services that the person has asked for. We can also stop providing services the person already has with us. A record of any fraud risk will be kept by the fraud prevention agencies and this could mean that other providers refuse to offer services, finances or employment. Fraud prevention agencies can hold onto someone's personal data for different periods, depending on the situation. If someone is considered a fraud risk, their data will be held for at least six years.

HOW WE COLLECT INFORMATION

We Collect Information Using Cookies and Other Technologies

In addition to collecting data directly from you, we use cookies, tracking pixels/web beacons and/or other technologies to receive and store certain types of information, including your Direct Identifiers and Internet Activity Information. Cookies are pieces of information that can be placed on your computer, tablet, or device for the purpose of facilitating and enhancing your communication and interaction with the Platform.

We use cookies and these other technologies to collect information as follows:

• Category 1: Strictly necessary. These cookies and other technologies are strictly necessary to enable you to use the Platform, for example, accessing your Account and providing you the service you have requested.
• Category 2: User choices. These cookies and other technologies allow us to remember the choices you have made, for example, your user name, language used, or country. They may be used for user preferences purposes.
• Category 3: Third-Party Analytics. These cookies and other technologies are placed by our third-party partners for web analytics purposes. Examples of these cookies and other technologies include Google Analytics and Adobe Analytics. You can opt out of Google Analytics by following the instructions provided at https://tools.google.com/dlpage/gaoptout.

Generally, you may stop or restrict the placement of our cookies on your computer by adjusting your web browser preferences, but please note that this may impact your ability to access your Account and use the Platform, for example, some cookies we place are to verify your identity and are therefore an important aspect of maintaining the security of your account.

We Collect Information from Other Sources

We may also obtain your personal information from third parties, including business partners, Know Your Client checks, consumer reporting agencies, affiliates, associated trust entities, and publicly available sources, that can enhance and add to our information about you (e.g., adding address information). This may improve our ability to contact you and improve the relevancy of our marketing by providing better recommendations or special offers that we think may interest you, and it also may prevent an account from being opened.

HOW WE PROTECT THE INFORMATION WE COLLECT

No method of transmission over the Internet, or method of electronic processing or storage, is fully secure. While we maintain reasonable security measures to protect the confidentiality and security of the information we hold, we cannot guarantee the security of your information. In the event that we are required by law to inform you of a breach of your information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

If you register for an Account, you will be asked to create a password. You are responsible for maintaining the confidentiality of your password and for any access to or use of your Account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us immediately of any unauthorized use of your password or Account.

HOW WE SHARE THE INFORMATION WE COLLECT

Our Affiliates and Associates

We may share your information with our corporate affiliates and associates (e.g., parent company, sister companies, associated trust entities, subsidiaries, joint ventures, or other companies under common control). We have a legitimate business interest to share data with our group as it allows us to understand better the performance of our services and how to offer and improve our product offerings across the group, (for example, to provide you with products or services, for marketing purposes, for internal reporting and where those companies provide services to us). It also assists us with finding operational efficiencies (such as financial efficiencies though sharing IT infrastructure), making use of group-level software solutions and improving our technological offerings that form an integral part of the Platform. This information will consist of public information, such as that listed in a phone book, or non-public information, such as your social security number, date of birth, identification number, etc.

We want you to get the most out of your relationship with our group, our affiliates, associated third parties and us. One of the ways we might help you do this is by using the contact details you've supplied us to send you marketing information about products or services we think you'll find interesting. For example, it might be an e-newsletter keeping you updated on what new products and services are available to you. We will only send this to you where we have a lawful basis to do so and you will be able to amend your preferences, details of which will be explained to you in relevant communication.

Service Providers

We share your information with non-affiliated third parties that provide services to us. Among other things, these non-affiliated third parties help us with the administration, operation, and marketing of the Platform and our product offerings across our group. This includes hosting, communications, printing, marketing, data enhancement, technical support, payment or transaction processing, and fulfillment of services.

Other Third Parties

We may share with other third parties with your permission or as permitted by law.

Legal Requirements

We may disclose information when we believe disclosure is appropriate to comply with the law, to enforce or apply applicable terms and conditions and other agreements, or to protect our rights, property or safety or the rights, property or safety of our affiliates or associated trust entities, users, or third parties. For example, for the purposes of “Know Your Customer” and other regulatory requirements, personal information may be screened against third-party identification services and government-provided databases, which return information regarding potential matches to publicly available information. We may also disclose information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.

When You Direct Us

We may share your information at your direction or request, either through the Platform, or otherwise.

With Your Consent

We may ask if you consent to share your information with other non-affiliated third parties who are not described elsewhere in this Privacy Policy, and may share your information with your consent.

Business Transfers

If another entity acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage. We also may retain a copy of that information.

HOW LONG WE RETAIN YOUR INFORMATION

We will retain your information for as long as necessary for the purposes described in this Privacy Policy and in accordance with the following principles:

• For the duration required pursuant to a legal obligation;
• For the period required by applicable law and regulations for the activities relating to the service; or
• For the duration of legal proceedings and the related limitation periods, for processing activities necessary to protect against legal liability and enforce our rights.

However, we may need to maintain records for a significant period. For example, we are subject to certain anti-money laundering laws, which require us to retain:

• A copy of the documents we used to comply with our customer due diligence obligations; and
• Supporting evidence and records of transactions with you and your relationship with us, for a period of six years after our business relationship with you has ended.

INTERNATIONAL DATA TRANSFERS

Where required and possible, we take steps to treat your information using the same privacy principles that apply pursuant to the law of the country in which we first received your data.

If you are located in the European Union (EU) or your data is otherwise governed by EU privacy laws, we may transfer your personal information to countries outside the EEA for processing in accordance with this Privacy Policy and as permitted by applicable laws. Where this is the case, we will ensure that any transfer is necessary for the performance of a contract between us or a contract in your interest and that legal protections are applied.

WHAT CHOICES AND RIGHTS YOU HAVE REGARDING YOUR INFORMATION

We offer you the rights and choices described in this section. Note that if your information was collected by another party under their privacy policy, we may refer you to that party in order to exercise the choices regarding your data.

Rectify Your Information

We rely on you to update and correct your information. Note that we may keep historical information in our backup files as permitted by law. If the Platform does not permit you to update or correct certain information, contact us at the address described below to ask us to rectify information that you think is inaccurate or incomplete.

Opting Out of E-mail, Telephone and Text Message Marketing

When we send you promotional emails based on your consent or as permitted by applicable laws, you have the right to unsubscribe. You also have the ability to unsubscribe to promotional e-mails by following the unsubscribe instructions in e-mails. Please allow us up to 10 business days to implement your request to unsubscribe. Note that even if you decide not to receive promotional emails, we may still send you service related communications.

We may distribute mobile coupons and text messages to your mobile device if you have requested this information via an opt-in request. You may opt out of receiving text messages and mobile coupons via the texts you receive.

If you do not wish to receive promotional telephone communication from us, email us at invest@yieldcrowd.com to opt out. This opt out does not apply to operational communication, for example, confirmation of delivery address.

Additional Rights for Individuals Located in Certain Jurisdictions, including the EEA

In some circumstances we may be subject to additional data protection laws that give you additional data protection rights, for example if you are located in certain jurisdictions. To the extent required by these applicable laws, we will grant you the following additional rights, provided we can adequately verify your identity:

• Access to Your Personal Information. You may request access to your personal information by contacting us. If permitted and required by law, we will grant you reasonable access to the data that we have about you.
• Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of data, or request that we delete your personal information by contacting us at the address described below. If permitted and to the extent required by law we will grant a request to delete personal information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, in pursuit of a legal action, to detect or monitor fraud, to resolve disputes, or to enforce our agreements with you.
• Objection to Certain Processing. You may object to our use of your personal information by contacting us. For example, for individuals located in the EU (or where EU data protection law otherwise applies) you have the right to object to direct marketing and in some circumstances the right to object to certain automated processing operations.
• Right to Restrict Processing. At your request, we will limit the processing of your information in certain circumstances, for example where: (i) you dispute the accuracy of your information; (ii) your personal information was processed unlawfully and you request a limitation on processing; (iii) we no longer need to process your information but you require your information in connection with a legal claim, or (iv) you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.
• Right to Rectification. Where permitted and required by law, you have the right to obtain the rectification of inaccurate personal data concerning you.
• Right to Data Portability. Where permitted and required by law, you have the right to receive your information in a structured, commonly used, and machine-readable format in certain circumstances.
• Revocation of Consent. You may revoke any prior consent for the processing of your personal information if we process your data based on consent. If you revoke your consent, then we may no longer be able to process your personal information or provide that part of the service that relies upon such consent. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so.

The right to equal service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our websites or services.

Please address written requests and questions about your rights to invest@yieldcrowd.com

Note that, as required by law, we will require you to prove your identity. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. We may also verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or address. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

ADDITIONAL INFORMATION

Important Notices and Transactional E-mail

From time to time, we may send to your email address non-commercial electronic email messages with important information about us or the Platform. Please note that any opt-out will not apply to other communications that will be provided to you or any entity or trust that you are the contact point for in relation to your transactions with us, in agreement with us, or where required by law.

Third Party Websites and Services

The Platform contains links to other websites and services not maintained by us or our affiliates or associates. In addition, other websites and services may also reference or link to the Platform. Use of such third-party websites is subject to the terms of use and privacy policies of those third parties. We do not control the privacy policies or practices of these third-party websites. We encourage you to be aware when you enter or leave the Platform, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

Compliance with State and Federal Laws

Certain regulations issued by state and/or federal government agencies may require us to maintain and report demographic information on the collective activities of our membership. We may also be required to maintain certain of your information to comply with applicable federal and state laws regarding recordkeeping, reporting and audits.

Do Not Track

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include Do Not Track instructions.

Privacy Policy Revisions

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an effective and last updated date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

HOW TO CONTACT US REGARDING THIS PRIVACY POLICY

If, at any time, you have questions or concerns about this Privacy Policy, please contact us through our contact page or at:

invest@yieldcrowd.com