Privacy Policy

CoFunder, LLC (“CoFunder”, “we”, “us”, “our”) is committed to respecting your privacy and using your information carefully and sensibly. This Privacy Policy describes what information we may collect about you and the ways we may use or share such information. By using cofunder.co (the “Site”), you accept all of the practices described in this Privacy Policy, as they may be updated by us from time to time in our sole discretion.

1. Information Collection Practices.

A. Information You Give Us. We collect and keep any information you enter on our Site or give us in any other manner. For example:

i. Information that you provide to us to set up a user account and identify you on the site, including user name, password, and secret questions and answers.

ii. Contact information, including first and last name, phone number, fax number, email address and mailing address.

iii. Payment information, including email address, bank account and routing number, and brokerage custodian account information.

iv. Profile information, including your investment preferences and other information you may provide us that allows us to customize your CoFunder experience.

v. Other information we are required by law to collect from you, or from regulatory agencies including the Securities and Exchange Commission (“SEC”), Financial Industry Regulation Authority (“FINRA”), and state securities regulators, to process securities-related transactions, and to comply with tax laws and anti-money laundering laws. This includes Social Security number, date of birth, gender, country of citizenship, liquid assets, net worth, education, occupation, employment status, employer contact information, annual income, CRD number, SEC number, tracking number used by state securities regulators, disclosures signed by your clients with respect to investment suitability, the discretionary nature of the account, and releases from liablility.

B. Information We Automatically Collect. We automatically track and collect the following categories of information when you visit our Site:

i. IP addresses;

ii. domain servers;

iii. types of computers and operating systems accessing the Site;

iv. types of web browsers used to access the Site and browser settings and plug-ins;

v. URL traffic to, through, and from the Site;

vi. deals viewed on the Site, including length of viewing

C. We may also obtain information about you through other sources such as credit agencies, SEC, FINRA, state securities regulators, affiliates and business partners.

D. Opt-Out. If you object to the collection of any of this information, you should not use the Site.

2. Use

We use the information we collect to:

A. Operate the Site.

B. Verify your identity and contact information.

C. Provide you with information and services you request.

D. Remember information so that you will not have to re-enter it during your visit or the next time you visit the site.

E. Provide custom, personalized content and information.

F. Set up your transaction accounts for you and your clients, issue account numbers and secure passwords, maintain your portfolio and deal activity, and contact you with account information.

G. Communicate with you about your transactions, service updates and other administrative issues.

H. Send you targeted marketing information with respect to deals based upon your interests and communications preferences.

I. Measure and improve our site and services.

J. Resolve disputes, address complaints and troubleshoot technical problems.

K. Analyze site and user behavior and prepare aggregated reports.

L. Comply with applicable laws and regulations.

3. Sharing and Disclosure

CoFunder does not sell, license, lease or otherwise disclose your personal information to any third party for purposes of marketing by the third party or for any reason, except as described below.

To provide our products and services, we may disclose your information to the following parties:

A. Portfolio Companies. If you invest in a CoFunder Fund, we share your information with the underlying companies in which we invest, “Portfolio Companies.” They will use the information only as necessary to complete your transactions and to include collect the information needed to register you and/or your clients as a shareholder of the issuer and issue the shares that you have purchased.

B. Our Affiliates. We may share information with present or future affiliates, including our subsidiaries, joint ventures or other companies under common control, where it may be used to provide joint services or for such purposes as internal statistics, strategic decision-making, customer reviews, identifying customer trends, customer verification, fraud prevention and security. You may limit our affiliates from marketing their products or services to you based on personal information that we collect about you and share with them. Your choice to limit marketing offers from our affiliates will apply until you tell us to change your choice. You can opt back in at any time. To limit affiliate marketing offers, contact us by e-mail at privacy@CoFunder.co.

C. Service Providers. We may share information with service providers under contract who help with our business operations and internal functions, for example, verifying our users, processing accounts, order fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business, maintaining the Site, and providing related services, such as electronic funds transfers and wires. Our service providers are required to protect personal information in a manner similar to the way we protect personal information and to use it only for the services they provide to us.

D. Legal and Other Disclosures. We may disclose information when permitted by law or under the good-faith belief that such disclosure is necessary under applicable law; to comply with legal process served on CoFunder; to protect the property or interests of CoFunder its agents and employees; or to protect personal safety or the public.

F. Assets. As our business evolves, CoFunder may sell, transfer or otherwise share some or all of its assets in connection with a merger, reorganization or sale of assets, or in the event of bankruptcy. In such an event, personal information may be one of the assets transferred.

4. Lost or Stolen Information

You must promptly notify us if your user name or password is lost, stolen, or used without permission. In such an event, we will remove that user name or password from your account and update our records accordingly.

5. How We Safeguard Your Information.

We take the protection of your personal information seriously, and we take commercially reasonable measures to safeguard it. If you register for an account with us, you will be required to secure it with a user-created password. Please note that we cannot guarantee the security of account information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time.

6. Links to Other Web Sites
We are not responsible for the practices employed by Web sites linked to or from our Site nor the information or content contained therein. Please remember that when you use a link to go from our Site to another Web site, our Privacy Policy is no longer in effect. Your browsing and interaction on any other Web site, including those that have a link on our Site, is subject to that Web site’s own rules and policies. Please read over those rules and policies before proceeding.

7. Governing Law.

By using the Site, you agree that this Privacy Policy is governed by Delaware law and that any and all controversies arising under this Privacy Policy shall be resolved exclusively by the state or federal courts located in New Castle County, Delaware.

8. Updates and Changes to Privacy Policy.

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site.

This Privacy Policy was last modified on August 11, 2017.