Last Updated: February 24, 2020
Welcome to Miventure, 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, offers various investment opportunities. The Miventure App and the Miventure website (https://www.miventure.com , the”Site”) are exclusively owned by Miventure Holdings, Inc. (“Miventure Holding”). Additional services on the App and Site may be provided by Miventure Solutions, LLC. (“Miventure Solutions”). Miventure Inc, Miventure Solutions, and Miventure Holdings may be referred to collectively as “Miventure,” “us,” “our,” “we.”
• The types of information we may collect or that you may provide when you interact with our App, our website: https://miventure.com (the “Site”), or otherwise engage with our products or services; and
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.
2. INFORMATION WE COLLECT AND HOW WE COLLECT IT
• Personal information required to verify your identity;
• Personal and financial information necessary to assess your eligibility to utilize the services available on the App;
• Non-identifiable and aggregated personal data pertaining to your App and Site visits that help us maintain the appropriate features, functionality and User experience.
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:Your name, address, phone number, email address, birth date, social security number, and other personal information.Copies of your correspondence via email, phone, or social media, if you contact us.Information needed to grant us access to your accounts on third-party sites (“Third-Party Sites”). The personal information collected from the Third-Party Sites may be used to register your User account and to provide some of our services.Your username and password.
Information that is about you individually does not identify you, such as your investment history and experience, investment portfolio, and your educational or professional history. 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:
• Financial information, including your social security number, income, and net worth.
• Copies of your tax returns, brokerage statements, W-2 forms, and other financial documents.
• Information to confirm your place of residence and your phone number.
• Information about your bank accounts or other sources of payment.
• Information to confirm your relationship with other parties associated with the Site, App or our services.
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
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:
• An individual’s physiological, biological, or behavioral characteristics that can be used, singly or in combination with each other or with other identifying data, to establish individual identity.
• Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
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:
• Verify that you are permitted to use and invest through the Platform.
• Keep track of your investments.
• Guard against fraud.
• Send you updates on your User account.
• Comply with applicable law.
• Answer your questions.
• Protect our rights.
• Send to third parties at your request.
• Process your transactions on the Platform.
• Determine whether your mobile device information is compatible with the Platform.
• Keep track of your use of the Platform.
• Send you information about your investments.
• Notify you of other investment opportunities.
• Analyze use of the Platform.
• Improve the Platform.
• Send you information about the Platform.
• Send you materials about us.
• Other purposes we disclose to you.
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:
• To business you invest in;
• To other Users;To third parties;
• To affiliates;
• To a buyer or other successor in the event of a Change of Control in Miventure Inc. or Miventure Solutions.
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.
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.
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.
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.
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:
• To confirm your registration.
• To provide you with legal notices.
• To notify you of new investment opportunities.
• When the online profile you created is changed.
• To ask you to participate in surveys, or otherwise provide feedback.
• To confirm your investment in a campaign.
• To notify you of any investment limitations.
• To ask you for information.
• Other purposes we disclose to you.
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.
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 email@example.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 firstname.lastname@example.org.