PRIVACY POLICY

 

Last Updated: June 17, 2020

 

1. INTRODUCTION

Welcome to Miventure Holdings, Inc. (“Miventure Holding”), a mobile application based online investment platform offered on iOS and Android (the “Platform” or the “App”) through which Miventure, Inc. (“Miventure Inc.”), a funding portal registered with the Securities and Exchange Commission (the “SEC”) and a member of FINRA, and Miventure Solutions, LLC (“Miventure Solutions”, collectively with Miventure Holding and Miventure Inc., referred to as “Miventure,” “us,” “our,” “we”), created to provide you with information about our services, including those relating to investment opportunities offered through our App.

At Miventure we respect the privacy of our App visitors (“you,” “your,” “User”) and are committed to protecting it through our compliance with this Privacy Policy (“Privacy Policy”). 

 

This Privacy Policy describes:

 

 

This Privacy Policy is part of our Terms of Service, and all the terms and conditions set forth in the Terms of Service also apply to this Privacy Policy. Please carefully review this Privacy Policy to learn about how we use your information. By using the App and/or the Site in any way you agree to this Privacy Policy. We may also ask you to indicate your consent more formally by checking a box or by taking an affirmative action within the Platform. If you have any questions or concerns regarding this Privacy Policy, you should contact us at info@miventure.com.

 

IF YOU DO NOT UNDERSTAND OR DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY PLEASE DO NOT USE THE SITE.

 

2. INFORMATION WE COLLECT AND HOW WE COLLECT IT

 

We collect personally identifiable and non-personal information from you when you visit the App or Site. The majority of information is collected during the registration and/or investment process and, and while some items are optional, most are required for legal or security purposes. In addition we may collect information through the use of cookies and certain Integrated Service Providers (as defined herein). You may choose to provide additional information during subsequent visits to the App or Site, but keep in mind that some of this information will be required if you wish to utilize the full scope of services we offer. In general, the type of information we collect includes, but is not limited to: 

Personal Information

When you download, register with, visit, browse, or otherwise interact with the App or Site, we may ask you to provide information including but not limited to:

If you decide to register through or otherwise grant access to a third party social networking or authentication service that we may make available, such as Apple, Facebook, LinkedIn, or Google, (generally, our "Integrated Service Provider"), we will collect certain personal information that you have provided to the Integrated Service Provider (such as your name, email address, photo, and other information you make available via the Integrated Service Provider) and an authentication token from the Integrated Service Provider. The personal information collected from the Integrated Service Provider may be used to register you on our App or Site and to provide some of the features we offer. You may revoke our access to your account with the Integrated Service Provider at any time by updating the appropriate settings in the account preferences of the respective Integrated Service Provider. You understand that certain features of our Platform may not be available to you if you choose to remove our access to your account with the Integrated Service Provider.

If you choose to invest through our App, we may collect information including but not limited to:

Personal Financial Information 

When you subscribe to make an investment in one of the offerings available on the Platform, you will again be asked for personal information. You will also be required to provide personal financial information, such as your bank routing number or swift code, and bank account number, to help to facilitate the subscription process.

Non-Identifiable Information and Aggregated Personal Information

We or our Integrated Service Providers may automatically collect certain information when you use our App or Site, including: (i) information about your interaction with our App or Site, including the actions you take, the pages or other content you view or otherwise interact with, and the dates and times of your visits; and (ii) device information, such as your IP address, operating system information, and web browser and/or device type and language. 

We or our Integrated Service Providers collect this information through the use of "cookies" and other technologies to better understand how our users navigate through our App or Site, learn what content is being viewed, and administer and improve our App or Site. Cookies are small text files that web servers place on an internet user’s computer or mobile device that are designed to store basic information and to recognize your browser or mobile device. We may use Google Analytics cookies for data analytics purposes. You can find more information on how Google uses data from these cookies at www.google.com/policies/privacy/partners/.

You may stop or restrict the placement of our cookies, Google's cookies and third party cookies on your computer, device or mobile phone by adjusting your web browser preferences or a “Do Not Track” setting in your web browser or by activating the appropriate setting on your mobile phone. You can also restrict marketing cookies by rejecting cookies on the website. If you do so, you may still use our Site or App, but this may interfere with some of its functionality.

You may also clear cookies from your computer or device via your web browser settings. You may also wish to use a Google Analytics opt-out web browser add-on. Information on this option is available at: http://support.google.com/analytics/bin/answer.py?hl=en&answer=2700409.

We may compile personal and other information on an aggregate basis that does not identify you individually. This information could include, without limitation, the number of Users who have registered to use our Platform, demographic information about Users of our Platform, and individual purchase preferences. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Policy, and for any other lawful purpose. 

Biometric Information 

If you choose to set up biometrics for logging into our App, we may collect “Biometric Information” from you in order to use functionalities such as Face ID or Touch ID. Biometric Information means:

 

3. HOW WE USE YOUR INFORMATION

We do not sell or rent personal information about our Users for marketing purposes. We do, however, share your personal information with our trusted partners who perform vital functions with respect to the investment opportunities on our App.

In addition, your investment profile information may, in a generic way, be made publicly available for use on the “Statistics” page of the App or in other summaries of aggregate investment data.

If you use our communications functionality on the App, you should be aware that any personally identifiable information you submit can be read, collected, or used by other Users of this forum and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit through this forum.

We use information that we collect about you or that you provide to us, including any personal information, to:

 

4. DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our Users, and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect, or you provide:

 

Businesses You Invest In 

We share your information with the businesses (the “Issuers”) that you invest in, which may include your personal information and information relating to your investment(s) in such Issuer. Issuers may choose to include you in their mailing lists for future communications with you, including for administrative, informational, promotional, and marketing purposes. Should you not wish to receive such communications from the Issuers you invest in, please contact the Issuer(s) directly.

Other Users

Please note that if you are a User on our Platform, your profile page is not viewable by other Users nor the public. All information you have shared with us is completely private except for your username which may be displayed when you submit or share any comments or information on public areas of the Platform, such as questions for founders of Miventure, which can be read, collected, or used by other users and the public. We are not responsible for the information you choose to submit or share on the public areas of our Platform, such as the communication channels on our business Users’ campaign pages.

Third Parties

We use third parties to perform services for the Platform, such as hosting services, electronic signature providers, electronic payment service providers, and services that verify the qualification of investors. Each of these third parties will need some of your personal and/or financial information to perform their services. 

We use Plaid Inc ("Plaid") to connect your bank account to the Miventure app for easy checkout when investing in a business. By signing up on the Miventure app as an investor, you consent to Plaid's Privacy Policy

We use Dwolla, Inc. (“Dwolla”) as a payment processor when you make an investment in a business and when you receive repayments. Dwolla processes payments via Automated Clearing House (ACH) transactions using your connected bank account as the source of funds. By signing up on the Miventure app as an investor, you consent to Dwolla's Privacy Policy

We use IDology, Inc. (“IDology”) and Investready Inc. (“Investready”) for identity verification and for investor status verification as required by securities and banking laws. By signing up on the Miventure app as an investor, you consent to IDology's Privacy Policy and Investready's Privacy Policy

Affiliates

We may provide information to one or more of our affiliates, meaning a company that we control or that is under common control with us. All of our affiliates will also be bound by the terms of this Privacy Policy.

Change of Control

If our company is sold, or otherwise bought in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Miventure’s assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Miventure about our Users is among the assets transferred, all information will be transferred to our successor. 

Other Disclosures

We may disclose information about you to third parties if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request, (b) to enforce our agreements, policies, or terms of service, (c) to protect the security or integrity of our Platform and/or Site, (d) to protect the property, rights, and safety of us, our users, or the public, (e) to respond in an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.

5. HOW WE PROTECT YOUR INFORMATION

The security of your information is important to us. We have implemented reasonable security measures to help protect the information in our care, including but not limited to, using Secure Sockets Layer encryption, the standard for secure Internet network connections, to protect information exchanged over the Internet between the App and our servers. 

However, no data transmission over the Internet or method of storage is 100% secure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App or Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone, and we urge you to be careful about giving out information in public areas of the App, such as message boards. The information you share in public areas may be viewed by any User of the App. As a result, while we strive to protect your information, we cannot and do not guarantee or warrant the security of information collected or otherwise obtained by us in connection with our App or Site.  We are not responsible for circumvention of any privacy settings or security measures we provide.

In addition, when you use our products or services you might be required or permitted to visit other websites. We take no responsibility for the security of their site and/or systems. 

 

6. COMMUNICATIONS FROM US

We may send you email and in-App notifications for the following reasons:

7. MODIFYING AND DELETING INFORMATION

To modify or delete information concerning your account or personal information, please log into your account and update your profile. We may retain certain information as required by law or for necessary business purposes. If you wish to suspend your account or need help modifying account information, please contact us at the email address below in ‘ Contact Us.’

8. OPT-OUT POLICY

We may at times send you e-mail communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional emails from us, or have your personal information used for any other direct marketing purposes, you have the right to opt-out and may unsubscribe completely by managing your preferences on the App or Site or contacting us on the Platform or over email. Please note that opt-out requests may take up to one (1) week to process. Please also note that at times we may need to send you email communications that are transactional in nature such as service or termination announcements or payment confirmations which are communications you will not be able to opt-out of.

If, after submitting a request to opt-out, you affirmatively subscribe to receive emails on individual offerings, issuers, or other focused subject matters, you will no longer be deemed to have opted out of those specific communications. You will, however, remain opted out for all other marketing and promotional emails.

9. CHANGES TO PRIVACY POLICY

Please revisit the Privacy Policy periodically to stay aware of any changes, which we may make from time to time. If we modify our Privacy Policy, we will make it available on our App and indicate the effective date. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change via email address, if we have one on file, or generate a pop-up or similar notification when you access our Platform for the first time after such material changes are made. Your continued use of our Platform after the revised Privacy Policy has become effective indicates that you have read, understood, and agreed to the current version of our Privacy Policy.

  

10. CHILDREN’S POLICY

Our App and/or Site are not intended for children under the age of 18, and we do not knowingly collect personal information from children under the age of 18. If we learn that we have collected the personal information from a User under the age of 18, we will take steps to delete the information. If you are aware that a User under 18 has provided us with personal information, please contact us at info@miventure.com.

 

11. CALIFORNIA RESIDENTS

California law requires that we provide you with a summary of your privacy rights under the California Consumer Privacy Act (the “California Act”) and the California Business and Professions Code. The California Act requires us to inform you, at your request, (1) the categories of personal information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The California Act further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or standard mail. When contacting us, please indicate your name, address, email address, and what personal information you do not want us to share with marketing partners. The request should be sent to the attention of our legal department and labeled "California Customer Choice Notice." Please allow 30 days for a response. There is no charge.

 

12. CONTACT US

Please send your privacy-related questions, complaints, and suggestions to: info@miventure.com.