Privacy Policy
Introduction
We at AccessFunding recognize that your privacy is essential and take it seriously. This Privacy Policy outlines AccessFunding's policies and procedures regarding the collection, use, and disclosure of your information when you access or use our Services. It also explains your privacy rights and how the law safeguards you. By using the Services, you consent to our use of your information in accordance with this Privacy Policy. We will not use or share your personal information with anyone except as described here. Capitalized terms not defined in this Privacy Policy carry the meaning given to them in our General Terms.
This Privacy Policy is designed to fulfill our transparency obligations under relevant laws, including the General Data Protection Regulation (GDPR) and applicable U.S. state privacy laws such as the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020 and related California Consumer Privacy Act Regulations, collectively referred to as 'CCPA'), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act.
Who We Are & How to Get In Touch
Your Rights. Under this Privacy Policy and applicable law in certain jurisdictions, you have the right to:
Request access to your Personal Data. In certain jurisdictions, you may request a copy of your Personal Data held by us in a portable, readily usable format and confirm its lawful processing. As applicable, you may also request details of the following, covering the 12 months preceding your request:
The categories of Personal Data collected about you and the sources of such data;
The business or commercial purpose for collecting your Personal Data; and
The categories of Personal Data disclosed, along with the categories of third parties with whom such data was shared (if applicable).
Request correction of your Personal Data. You may request that any incomplete or inaccurate information we hold about you be corrected.
Request erasure of your Personal Data. You may request that we delete or remove your Personal Data when there is no valid reason for continued processing.
Object to processing of your Personal Data. If we are processing your Personal Data on the basis of a legitimate interest and there is a reason specific to your situation, you may object to such processing. You also have the right to object if we process your data for direct marketing purposes.
Request restriction of processing of your Personal Data. This allows you to ask us to suspend the processing of your Personal Data in specific cases (for example, if you want us to verify its accuracy or reason for processing).
Request transfer of your Personal Data. In certain jurisdictions, you may request that we provide your Personal Data in a structured, commonly used, machine-readable format to you or a third party of your choice. This applies only to automated data processing based on your consent or a contract with you.
Request to limit use and disclosure of your Sensitive Personal Data. In certain jurisdictions, you may request that we limit the use and disclosure of your Sensitive Personal Data (such as social security number, driver’s license, passport number, financial data, etc.) to purposes permitted by law.
Request to stop selling your Personal Data or sharing your Personal Data for cross-context behavioral advertising. AccessFunding does not sell your Personal Data. However, if applicable law permits, you may request that we limit the sharing of your Personal Data for behavioral advertising purposes.
Opt out of targeted advertising. In certain jurisdictions, you may opt out of targeted advertising based on your activities across websites and applications.
Opt out of profiling. AccessFunding does not process Personal Data for profiling that results in legal or similar significant effects. Should we engage in such activities in the future, depending on your jurisdiction, you may request us to stop.
Withdraw consent. Where consent is the basis for processing your Personal Data, you may withdraw it ("Consent Withdrawal"). Withdrawing consent may limit access to certain features. We will inform you of any limitations at the time you withdraw consent.
How to Exercise Your Rights. To exercise any of the rights above, contact us at privacy@accessfunding.ai.
Generally, there is no fee for accessing your Personal Data (or to exercise other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive, or we may refuse to comply in such cases.
We may need to verify your identity before responding to your request as a security measure to protect your Personal Data. Additional information may be requested to expedite our response.
Response Time. We aim to respond within one month. If your request is complex or there are multiple requests, it may take longer. We will keep you informed of any delays. If we decline to act on your request, you may request an appeal by contacting privacy@accessfunding.ai.
Non-Discrimination. AccessFunding will not discriminate against you for exercising any of these rights.
Complaints. If you wish to submit a complaint regarding this Privacy Policy or our data practices, please contact us at privacy@accessfunding.ai. We will respond promptly to resolve your concern.
Marketing and Communication Preferences
You can request to stop receiving marketing messages or adjust your email preferences at any time through the opt-out links in any marketing message sent to you. Opting out of marketing messages will not affect Personal Data provided to us for emails related to existing or pending transactions, investments, or consented direct marketing communications."
What Personal Data We Collect
AccessFunding uses the Personal Data we collect to deliver our Services, personalize content, retain information to streamline your Account access, analyze how the Services are used, diagnose service or technical issues, maintain security, monitor metrics like total visitors, traffic, and demographic trends, and track user content and activity as required to comply with applicable laws.
Information You Directly Provide to Us. While using the Services, you may provide information that could personally identify you ("Personal Data"). The types of Personal Data we may collect from you are outlined below:
Identity Data: First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, picture, signature, and/or tax identification number, password, copies of ID cards or other forms of identification.
Contact Data: Home address, work address, billing address, email address, and telephone numbers.
Professional Background Data: Educational and professional history, interests, and accomplishments.
Online Presence Data: Links to your public social media profiles, personal websites, and other online materials related to you.
Financial Data: Bank account and payment card details, statements about your financial situation, and overall wealth.
Transaction Data: Details of payments to and from you, subscriptions, services purchased from us, and transactions with third parties (such as credit history).
Investment Data: Investment objectives, experience, prior investments (both online and offline), syndicates or leads backed, investment amounts, preferences, and details provided in subscription documents for deals closed via our Investing Platform. Also includes information about personal investment entities, co-owners, beneficiaries, and tax-related data.
Content Data: Content you post on the Services that doesn’t fall into another category, such as profiles, questions, preferences, answers, messages, comments, and other contributions, along with metadata (e.g., timestamps).
Marketing and Communications Data: Preferences for receiving marketing from us or third parties, and your communication preferences. If you correspond with us via email or messaging through the Services, we may retain the content of these messages and our responses.
Behavioural Data: Inferred or assumed information about your behavior and interests based on your online activity, often categorized into "segments."
Technical Data: Internet protocol (IP) address, general geolocation (derived from IP address), login data, browser type and version, time zone and location, browser plug-in types and versions, operating system, platform, and other technology on devices used to access the Site or Services.
Personal Data from Third Party Sources
In addition to the Personal Data we collect directly from you (as described in the previous section), we may also collect certain Personal Data about you from third-party sources, some of which may not be publicly available. Examples of these sources include:
Social Media Sites:
Identity Data
Contact Data
Online Presence Data
Our Affiliates:
Identity Data
Contact Data
Marketing and Communications Data
Behavioral Data
Investment Data
Transaction Data
Financial Data
Content Data
Analytics Providers:
Behavioral Data
Technical Data
Advertisers:
Behavioral Data
Technical Data
Data Brokers:
Identity Data
Contact Data
Behavioral Data
Technical Data
Online Presence Data
Identity Verification and Compliance Service Providers:
Identity Data
Contact Data
Aggregated Data
We may collect, use, and share "Aggregated Data," such as statistical or demographic data, for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form, it no longer constitutes Personal Data under applicable laws like CCPA, as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data in a way that directly or indirectly identifies you, we treat the combined data as Personal Data, which will be used in accordance with this Privacy Policy.
No Special Categories of Personal Data and Sensitive Personal Data
We do not collect any "Special Categories of Personal Data" (including information about race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, health, or genetic and biometric data). However, certain Personal Data we collect may be considered "sensitive personal information" ("Sensitive Personal Data") under applicable law. We use and disclose Sensitive Personal Data only for business and compliance purposes and other legally authorized purposes.
Keeping It Respectful
We use your Personal Data for various purposes, including to deliver and enhance our Services; manage your Account and provide customer support; conduct research and analysis on how you use the Services; develop, display, and track content and advertising tailored to your interests within the Services and on other sites (including potentially displaying our advertisements when you visit other websites); conduct website or mobile application analytics; diagnose and resolve technical issues; automatically update the Services on your device; verify your identity and prevent fraud or unauthorized or illegal activities; and enforce or exercise rights under our Terms.
For each purpose where we use your Personal Data, applicable law may require us to have a legal basis for that use. These legal bases depend on the specific Services you use and how you use them. Accordingly, we collect and use your Personal Data only where:
Service Provision: We need it to provide the Services, operate and maintain the Services, offer customer support, enable personalized features, and protect the safety and security of the Services.
Contractual Necessity: Processing of your Personal Data is necessary to perform a contract to which you are a party or to protect your vital interests or those of another individual.
Legitimate Interests: It fulfills a legitimate interest (that is not overridden by your data protection rights), such as for research and development, to market and promote the Services, or to protect our legal rights and interests.
Legal Compliance: Processing is necessary to comply with a legal or regulatory obligation.
In some cases, we may rely on your consent as the legal basis for using your Personal Data where we have specifically sought it for a particular purpose. If we rely on your consent, you have the right to withdraw it at any time (though this will not affect any processing that has already occurred). Below, we provide a detailed table of examples for each purpose where we may use your Personal Data.
What Happens if You Do Not Provide Necessary Personal Data?
If we need to process your Personal Data to comply with legal requirements or to fulfill the terms of a contract we have with you, and you do not provide the requested data, we may not be able to perform the contract we have or are attempting to enter into with you (for example, to provide certain functionalities within our Services). In such cases, we may need to restrict or prevent your access to the Services.
Who We Share Your Personal Data With
We may share your Personal Data with third parties in the ways that are described below. We consider this information to be a vital part of our relationship with you.
Our Affiliates
Our affiliates may access your Personal Data to assist us in developing, maintaining, and providing our Services, as well as managing customer relationships (including customer support, client communications, fund advisory services, etc.).
Service Providers
Our service providers support our Services by providing website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other essential services, which may require them to access or use your Personal Data.
Professional Advisers
Our legal, accounting, banking, audit, and insurance advisors may need to review your Personal Data to provide consultancy, compliance, banking, legal, insurance, accounting, and similar professional services.
AccessFunding Customers with Whom You Are Doing Business
Third-party fund managers or other AccessFunding customers managing certain funds in which you may invest may access your Personal Data to provide, develop, and maintain their services, and to manage their relationships with you. These parties may include:
Third-party fund managers who oversee specific funds available on our platform.
Other AccessFunding customers managing investment tools and services, who may use AccessFunding’s tools in connection with your investments.
These customers or third-party fund managers may also share your Personal Data with their service providers and professional advisers (e.g., lawyers, accountants, bankers, auditors, insurers) for additional support, including fund administration, banking services, consultancy, compliance, legal, and accounting services.
Legal and Tax Authorities, Regulators, and Judicial Participants
We may disclose your Personal Data as reasonably necessary to comply with laws, regulations, orders, subpoenas, rules of self-regulatory organizations, or audits. We may also disclose data to protect safety, address fraud, security, or technical issues, or safeguard our legal rights and interests and those of others, including in the context of acquisitions, mergers, or business sales.
Advertisers
Certain users of the Services may access your Personal Data to interact with you and offer opportunities that align with your background and preferences. Additionally, third parties, such as ad servers or ad networks, may be granted access to provide advertising tailored to your interests.
Researchers
To enhance public understanding of market trends, we may provide Personal Data to third-party researchers, including academics or contractors, under confidentiality obligations for research purposes.
API Users
A select number of partners have API access to portions of our platform. Common uses include OAuth and anti-money laundering (AML) or accreditation verification for potential investors.
Public Display of Personal Data
Personal Data you choose to add to your profile may be publicly viewable on the Site. If you are a fund manager, most of your content will be accessible to other users. You may request that your information be shown only to a select group of investors, and we will make every effort to limit disclosure to those investors. However, we cannot guarantee that no one else will see your information, nor do we control how users with access will use it. If you wish to keep your information private, avoid sharing it with other users on our Site.
If you are an investor, certain content may not be accessible to other users, but some users may still be able to infer details about your income or net worth based on your qualifications as an investor. Additionally, fund advisers and lead investors may have access to your Personal Data to assist in evaluating, inviting, and communicating with you as an investor. AccessFunding may also display limited information about your status as an investor in a particular fund or venture.
Corporate Transactions
As we grow our business, we may acquire or divest businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, we may transfer your Personal Data as part of the transaction without your consent or prior notice.
Sharing Non-Personal Data
We may share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, click counts, etc.) with third parties to help them understand usage patterns of our Services or conduct independent research based on this anonymized data.
Requests for Data Removal
If you request the removal of your Personal Data (as described in the Your Rights Relating to Your Personal Data section), we will relay this request to any third party with whom we have shared your data. However, we are not responsible for updating or removing Personal Data previously obtained by any third party in accordance with this policy or by any third party to whom you have provided this information directly (whether by sharing your login credentials or otherwise).
How Long We Store Your Personal Data
We will retain your information for as long as your account is active or as reasonably necessary for the purposes outlined in How We Use Your Personal Data and Why, unless you request its removal as described in Your Rights Relating to Your Personal Data. We will retain your Personal Data only for as long as needed for these purposes unless a longer retention period is required by law (e.g., for regulatory compliance). This may include keeping your Personal Data after account deactivation for the time needed to support legitimate business interests, conduct audits, comply with legal obligations, resolve disputes, and enforce agreements.
Where We Will Store Your Personal Data
The Services are maintained in Canada. Personal Data you provide may be stored, processed, and accessed by us, our staff, subcontractors, and third parties with whom we share data in Canada or other locations for the purposes described in this policy. We may also store Personal Data in locations outside of AccessFunding’s direct control (for example, on servers or databases hosted by third-party providers).
While we welcome users worldwide, by accessing the Services and providing your Personal Data, you consent to the transfer, storage, and processing of your data in Canada, as outlined in this Privacy Policy. Please note that Canadian data protection laws may not be as comprehensive or protective as those in your country of residence.
How We Protect Your Personal Data
AccessFunding uses industry-standard physical, managerial, and technical safeguards to protect the integrity and security of your Personal Data. We restrict access to your Personal Data to employees and staff with a legitimate business need, all of whom are bound by contractual confidentiality obligations. Our policies and procedures are regularly reviewed to ensure their effectiveness and to keep them current. However, we cannot guarantee the security of any information you transmit to AccessFunding or that your information on the Services will not be accessed, disclosed, altered, or destroyed due to a breach of our safeguards.
We have procedures in place to address any actual or suspected Personal Data breach. In the event of a security breach that compromises your personal information, AccessFunding may promptly notify affected individuals by posting a notice on the Site, through the Services, or via email. You may also have a legal right to receive this notice in writing.
Please note that AccessFunding cannot ensure the protection, control, or management of your Personal Data in line with this Privacy Policy if you share your login and password information with any third party, including any third party operating a website or providing other services.
Our Policy on Children's Privacy
Protecting the privacy of young children is especially important to us. The Services are not intended for children under 16, and AccessFunding does not knowingly collect or solicit personal information from anyone under 16 or knowingly allow them to register for the Services. If you are under 16, please do not submit any personal information through the Site. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information on this Site. If we become aware that we have collected personal information from a child under 16, we will take steps to delete that information promptly.
Links to Other Websites
This Privacy Policy applies only to our Services. The Services may contain links to other websites not operated or controlled by AccessFunding. We are not responsible for the content, accuracy, or opinions expressed on such websites, and these websites are not investigated, monitored, or checked for accuracy or completeness by us. Please remember that when you follow a link from our Services to another website, our Privacy Policy no longer applies. Your browsing and interactions on any other website, including those linked on our Site, are subject to that website's own rules and policies. These third parties may use their own cookies or other methods to collect information about you.
Third Party Applications
If you choose to use third-party apps, websites, or services that integrate with our Services, these third parties may receive information about your activity within those apps and details from your public profile on our Site. If you enable, access, or use third-party apps linked through our Services, including integrating such apps into your instance of the Services, your use is governed solely by the privacy and cookies policies of those third-party apps. We encourage you to review the privacy and cookies policies of any third-party apps you decide to use. In some cases, you may need to register or log into these third-party apps on their own platforms. By enabling and integrating selected third-party apps, you expressly permit AccessFunding to share your login information and data with these third-party apps as necessary to support their integration and use within our Services.
Changes to our Privacy Policy
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will take effect immediately upon posting to this page. We encourage you to review this Privacy Policy regularly for any changes. You can determine if updates have been made by checking the Effective Date below. Your continued use of our Site after any changes to this Privacy Policy are posted indicates your consent to those changes.
It is important that the Personal Data we hold about you remains accurate and up-to-date. Please notify us if your Personal Data changes during your relationship with us.
Effective Date
This Privacy Policy was last updated on October 30, 2024.