Privacy Policy

Effective Date: January 9, 2017

This privacy policy explains how investorflow.org handles your personal information and data. We value your trust, so we’ve strived to present this policy in clear, plain language instead of legalese. The policy is structured so you can quickly find answers to the questions that interest you the most.

investorflow.org is a project of Realize Impact, which is a 501(c)(3) nonprofit organization registered in the United States. This privacy policy applies to all the products, services and websites offered by Realize Impact and its project investorflow.org (which together are hereinafter referred to as “investorflow.org”), except where otherwise noted. We refer to those products, services and websites collectively as the “services” in this policy. Some services may have supplementary privacy statements that explain in more detail our specific privacy practices in relation to them. Unless otherwise noted, our services are provided by investorflow.org.

EU – U.S. Privacy Shield. investorflow.org intends to participate in and certify compliance with the EU-U.S. Privacy Shield Framework. investorflow.org is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

When investorflow.org receives personal information under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on investorflow.org’s behalf, investorflow.org has certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) investorflow.org is responsible for the event giving rise to the damage. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, investorflow.org is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. In certain situations, investorflow.org may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Please contact investorflow.org if you have any concerns or complaints of any nature. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

U.S. – Swiss Safe Harbor. investorflow.org intends to comply with the US-Swiss Safe Harbor Framework developed by the U.S. Department of Commerce regarding the collection, use and retention of personal information received in the U.S. from Switzerland. investorflow.org intends to certify that it adheres to the U.S.-Swiss Safe Harbor Privacy Principles with respect to such information. investorflow.org may process some data from individuals or companies in Switzerland via other compliance mechanisms, including data processing agreements based on the EU Standard Contractual Clauses. To learn more about the Safe Harbor program, and to view our forthcoming certification when it is available, please visit https://safeharbor.export.gov/swisslist.aspx.

Questions? For questions regarding our privacy policy or practices, contact us.

Key Privacy Points: The Stuff You Really Care About

IF YOU POST DEALS:

  • We safeguard respondents’ email addresses. To make it easier for you to post deals on our website and share them with like-minded impact investors via email, you may upload lists of email addresses, in which case investorflow.org acts as a mere custodian of that data. We don’t sell these email addresses and we use them only as directed by you and in accordance with this policy.
  • We hold your data securely. Read our forthcoming Security Statement for more information.
  • Data is stored on servers located in the United States. More information about this is available if you are located in Europe. investorflow.org will process your data on your behalf and under your instructions (including the ones agreed to in this privacy policy).

IF YOU REVIEW DEALS:

  • Deals are administered by investors who post deals. Investors may post any number of deals on our website using our services. We host the deals on our website and collect responses that you submit to the investor who posted the deal. If you have any questions about a deal you are responding to, please contact the investor who posted the deal directly because investorflow.org is not responsible for the content of that deal or your responses to it. The investor who posted a deal is usually the same person that invited you to review the deal and sometimes they have their own privacy policy.
  • We don’t sell your responses to third parties. investorflow.org doesn’t sell or share your responses to deals with third party advertisers or marketers. investorflow.org merely acts as a custodian of data on behalf of the investor who posted a deal.
  • If you think a posted deal violates our Terms of Use or may be engaging in illegal activity, contact us to report it.

Deal Post Creators & Deal Reviewers

investorflow.org is used by investors who post deals (hereinafter referred to as deal post creators) and deal reviewers (people who consider these deals and may respond to them). The information we receive from deal post creators and deal reviewers and how we handle it differs, so we have split this privacy policy into two parts. See the section below that applies to you:

PRIVACY FOR DEAL POST CREATORS

1. What information does investorflow.org collect?

When you use investorflow.org, we collect information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.

Information we collect directly from you

  • Registration information. You need an investorflow.org account before you can post or review deals on investorflow.org. When you register for an account, we collect your username, password, email address and other information. If you choose to register by using a third party account (such as your LinkedIn account), please see “Information from third parties” below.
  • Billing information. If you make a payment to investorflow.org, we require you to provide your billing details, such as a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder.
  • Account settings. You can set various preferences and personal details. For example, your communication preferences (e.g., how often you receive emails about deals posted by other investors that match your impact investing interests).
  • Address book information. We allow you to import email addresses into an Address Book and easily invite people via email to review deals that you post. We don’t use these email addresses for our own purposes or email them except at your direction.
  • Deal data. We store your deal data (deals you post and deals you respond to) for you.
  • Other data you intentionally share. We may collect your personal information or data if you submit it to us in other contexts. For example, if you provide us with a testimonial.

We don’t share or abuse email addresses that you upload. Rest assured, investorflow.org will not email your deal recipients or people in your Address Book except at your direction. We definitely don’t sell those email addresses to any third parties.

Information we collect about you indirectly or passively when you interact with us

  • Usage data. We collect usage data about you whenever you interact with our services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps.
  • Device data. We collect data from the device and application you use to access our services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.
  • Referral data. If you arrive at an investorflow.org website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
  • Information from third parties. We may collect your personal information or data from third parties if you give permission to those third parties to share your information with us. For example, you have the option of registering and signing into investorflow.org with your LinkedIn account details. If you do this, the authentication of your logon details is handled by LinkedIn and we only collect information about your LinkedIn account that you expressly agree to share with us at the time you give permission for your investorflow.org account to be linked to your LinkedIn account.
  • Information from page tags. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics. Emails sent by investorflow.org or by users through our services may include page tags that allow the sender to collect information about who opened those emails and clicked on links in them. We do this to allow the email sender to measure the performance of their email messaging and to learn how to improve email deliverability and open rates.

2. How does investorflow.org use the information we collect?

We treat your deal posts and responses as information that is private to you. We know that, in many cases, you want to keep your deal posts and responses (which we collectively refer to as “deal data”) private. We do not use your deal data other than as described in this privacy policy or unless we have your express consent. We do not sell your deal data to third parties without your permission.

Generally, we use the information we collect from you in connection with providing our services to you and, on your behalf, to your deal post recipients. For example, specific ways we use this information are listed below. (See the next section of this privacy policy to see who we share your information with.)

  • To provide you with our services.
    • This includes providing you with customer support, which requires us to access your information to assist you (such as with deal post design and creation, or technical troubleshooting).
    • If you choose to link your investorflow.org account to a third party account (such as your LinkedIn account), we may use the information you allow us to collect from those third parties to provide you with additional features, services, and personalized content.
    • In order to provide you with useful options to use the services together with social media and other applications, we may give you the option to export information to, and collect information from, third party applications and websites, including social networking sites such as LinkedIn. When exporting and collecting such information, you may be disclosing your information to the individuals or organizations responsible for operating and maintaining such third party applications and sites, and your information may be accessible by others visiting or using those applications or sites. We do not own or operate the applications or websites that you connect with, and you should review the privacy policies and statements of such websites to ensure you are comfortable with the ways in which they use the information you share with them.
  • To manage our services. We internally use your information, including certain deal data, for the following limited purposes:
    • To monitor, maintain, and improve our services and features. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, deal post and response data, and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features. We may use your information for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, marketing, research and development purposes.
    • To enforce our Terms of Use.
    • To prevent potentially illegal activities.
    • To screen for and prevent undesirable or abusive activity. For example, we screen content for phishing activities, spam, and fraud.
  • To create new services, features or content. We may use your deal data and metadata (that is, data about the characteristics of a deal post and responses) for our internal purposes to create and provide new services, features or content. In relation to deal metadata, we may look at statistics like response rates, and deal post and response word counts, and publish interesting observations about these for informational or marketing purposes. When we do this, neither deal post creators nor deal post reviewers will be identified or identifiable unless we have obtained their permission.
  • To facilitate account creation and the logon process. If you choose to link your investorflow.org account to a third party account (such as your LinkedIn account), we use the information you allowed us to collect from those third parties to facilitate the account creation and login process.
  • To contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You can’t opt out of these communications since they are required to provide our services to you.
  • To contact you for marketing purposes. In the future, we intend only to do this if you have consented to our contacting you for this purpose. For example, during the account registration process we may ask for your permission to use your information to contact you for promotional purposes. You may opt out of these communications at any time by clicking on the “unsubscribe” link in them, or changing the relevant setting on your profile.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

3. With whom do we share or disclose your information?

We don’t sell your deal post or response data, unless you expressly permit us to!

When might we disclose your deal data to third parties? Only for a limited number of reasons. We share your information with our service providers who help us to provide our services to you. We contractually bind these service providers to keep your information confidential and to use it only for the purpose of providing their services. For example, we use payment processors who help us to process credit card transactions. By using our services, you authorize investorflow.org to sub-contract in this manner on your behalf. In rare circumstances, we may share information if required by law, or in a corporate restructuring or acquisition context (see below for more details).

We recognize that you have entrusted us with safeguarding the privacy of your information. Because that trust is very important to us, the only time we will disclose or share your personal information or deal data with a third party is when we have done one of three things, in accordance with applicable law: (a) given you notice, such as in this privacy policy; (b) obtained your express consent, such as through an opt-in checkbox; or (c) de-identified or aggregated the information so that individuals or other entities cannot reasonably be identified by it. Where required by law, we will obtain your express consent prior to disclosing or sharing any personal information.

We may disclose:

  • Your information to our service providers. We use service providers who help us to provide you with our services. We give relevant persons working for some of these providers access to your information, but only to the extent necessary for them to perform their services for us. We also implement reasonable contractual and technical protections to ensure the confidentiality of your personal information and data is maintained, used only for the provision of their services to us, and handled in accordance with this privacy policy. Examples of service providers include payment processors, hosting services, email service providers, and web traffic analytics tools.
  • Your account details to your billing contact. If your details (as the account holder) are different to the billing contact listed for your account, we may disclose your identity and account details to the billing contact upon their request (we also will usually attempt to notify you of such requests). By using our services and agreeing to this privacy policy, you consent to this disclosure.
  • Your email address to your organization. If the email address under which you’ve registered your account belongs to or is controlled by an organization, we may disclose that email address to that organization in order to help it understand who associated with that organization uses investorflow.org, and to assist the organization with its enterprise accounts.
  • Aggregated or de-identified information to third parties to improve or promote our services. No individuals can reasonably be identified or linked to any part of the information we share with third parties to improve or promote our services.
  • Your information if required or permitted by law. We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.
  • Your information if there’s a change in business ownership or structure. If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation), you expressly consent to investorflow.org transferring your information to the new owner or successor entity so that we can continue providing our services. If required, investorflow.org will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.
  • Information you expressly consent to be shared. For example, we may expressly request your permission to provide your contact details to third parties for various purposes, including to allow those third parties to contact you for marketing purposes. (You may later revoke your permission, but if you wish to stop receiving communications from a third party to which we provided your information with your permission, you will need to contact that third party directly.)

4. What are your rights to your information?

You can:

  • Update your account details. You may contact us to request such updates, which we will endeavor to make as soon as possible.
  • Access and correct your personal information. As an account holder, you may request corrections to certain personal information that investorflow.org holds about you.  Some account holders and other individuals (including those whose information we receive under the EU-U.S. Privacy Shield and the U.S.-Swiss Safe Harbor) have certain legal rights to obtain information of whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances.  In all cases, requests to exercise these rights may be directed to our customer support team. These rights are subject to some exceptions, such as where giving you access would have an unreasonable impact on the privacy of other individuals. We will respond to your request to exercise these rights within a reasonable time and, where required by law or where we deem it otherwise appropriate and practicable to do so, we will honor your request.
  • Cancel your account. To cancel and delete your account, please contact customer support. Deleting your account will disable your access to any services that require an investorflow.org account. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).

5. Security, cookies and other important information

Changes to this privacy policy. We may modify this privacy policy at any time, but if we do so, we will notify you by publishing the changes on this website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of these changes, you do not cancel your account and continue to use our services beyond the advance-notice period, you will be considered as having expressly consented to the changes in our privacy policy. If you disagree with the terms of this privacy policy or any updated privacy policy, you may close your account at any time.

  • Security. We intend to make available details about investorflow.org’s security practices in a Security Statement. We are committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the Internet. If you have any questions about the security of your personal information, contact customer support.
  • Data locations. Our servers are based in the United States, so your personal information will be hosted and processed by us in the United States. Your personal information may also be processed in, or transferred or disclosed to, countries in which investorflow.org subsidiaries and offices are located and in which our service providers are located or have servers.
  • Cookies. We and our partners use cookies and similar technologies on our websites. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:
    • To make our site easier to use. If you use a “Remember me” feature when you sign into your account, we may store your username in a cookie to make it quicker for you to sign in whenever you return to investorflow.org.
    • For security reasons. We use cookies to authenticate your identity, such as confirming whether you are currently logged into investorflow.org.
    • To provide you with personalized content. We may store user preferences, such as your default language, in cookies to personalize the content you see.
    • To improve our services. We use cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services and optimize the content we display to users.
    • To advertise to you. We, or our service providers and other third parties we work with, may place cookies when you visit our website and other websites or when you open emails that we send you, in order to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. For instance, we may evaluate which ads are clicked on most often, and whether those clicks lead users to make better use of our tools, features and services. If you don’t want to receive ads that are tailored to you based on your anonymous online activity, you may “opt out” of many of the companies that are involved in such tailoring by going to http://www.aboutads.info. Opting out in this way does not mean you will not receive any ads; it just means that you will not receive ads from such companies that have been tailored to you based on your activities and inferred preferences.
    • Google Analytics. In addition to the above, we intend to implement on our websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.
  • We don’t believe cookies are sinister, but you can still choose to remove or disable cookies via your browser. Refer to your web browser’s configuration documentation to learn how to do this. Please note that doing this may adversely impact your ability to use our services. Enabling cookies ensures a smoother experience when using our websites. To manage flash cookies, click here. By using our websites and agreeing to this privacy policy, you expressly consent to the use of cookies as described in this policy.
  • Blogs and Forums. Our websites may offer blogs and community forums accessible to users of our services. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We’re not responsible for any personal information you choose to submit in these areas of our site. To request removal of your personal information from our blog or community forum, contact customer support. In some cases, we may not be able to fulfill your request and we will let you know why. Commenting systems on our blogs are managed by a third party application that may require you to register to post a comment. Please review that application’s privacy policy to learn how the third party uses your information.
  • Online Tracking. We currently do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our websites or use our services (unless otherwise stated in a service-specific privacy statement).
  • Safety of Children and COPPA. Our services are not intended for and may not permissibly be used by individuals under the age of 13. investorflow.org does not knowingly collect personal data from persons under 13 or allow them to register. If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
  • English version controls. Non-English translations of this privacy policy may be provided for convenience. In the event of any ambiguity or conflict between translations, the English version is authoritative.

Consents. By clicking “I Agree” or any other button indicating your acceptance of this privacy policy, you expressly consent to the following:

  • You consent to the collection, use, disclosure and processing of your personal data in the manner described in this privacy policy, including our procedures relating to cookies, IP addresses and log files.
  • Our servers are based in the United States, so your personal data will be primarily processed by us in the United States. You consent to the transfer and processing of your personal data in the United States by investorflow.org and in the data locations identified in Section 5 by our various affiliates and service providers.
  • You consent and agree that we may transfer your data to data processors located in countries, including the United States, which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area. Your consent is voluntary, and you may revoke your consent by opting out at any time. Please note that if you opt-out, we may no longer be able to provide you our services.
  • You consent to us sharing your personal data with relevant persons working for service providers who assist us to provide our services.
  • If you have enabled cookies on your web browser, you consent to our use of cookies as described in this privacy policy.

6. Additional information for Japanese users

  • You agree that you are responsible for notifying the respondents of deals that you post using our services about how investorflow.org may use the respondents’ deal responses and personal data as described in this privacy policy and obtaining prior consent from respondents to disclose their personal data to investorflow.org.

7. Additional information for Brazilian users

  • The personal information collected, stored, used and/or processed by investorflow.org, as described in this privacy policy, are collected, stored, used and/or processed in accordance with Brazilian Law No. 12,965/2014. By clicking “I Agree” or any other button indicating your acceptance of this privacy policy, you expressly consent to the collection, use, storage and processing of your personal information by investorflow.org as described.

8. Additional information for Australian users

  • If you are dissatisfied with our handling of your complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (OAIC) by contacting the OAIC using the methods listed on their website at http://www.oaic.gov.au. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.

 

PRIVACY FOR DEAL RESPONDENTS

1. What information does investorflow.org collect?

When you respond to deals hosted by investorflow.org, we collect, on behalf and upon instructions (including the ones provided in this privacy policy) of deal post creators, information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.

Information we collect directly from you

  • Deal post responses. We collect and store the deal post responses that you submit.

→ Are your deal post responses anonymous? Deal post responses are provided to the deal post creator along with identifying information from your investorflow.org profile that is visible to other investors on our website, such as your name, organization, and geographic and impact goal preferences. Information on your profile that you have chosen to hide from other investors using our platform is not shared with the deal post creator, who has the ability to contact you via our website only after you have responded to the deal they have posted.

Information we collect about you from other sources

  • Usage data. We collect usage data about you whenever you interact with our services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, as with most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps. Note that we do not link this usage data to your deal responses.
  • Device data. We collect data from the device and application you use to access our services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.
  • Information from page tags. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics.
  • Your email address. If a deal post creator uses our website to send you a deal invitation email, we collect your email address when the deal post creator provides it to us. We don’t use this to send you email except at the direction of a deal post creator. The emails we send on behalf of a deal post creator appear to come from that deal post creator’s email address. If you no longer want to be contacted by a deal post creator, please contact the deal post creator directly.

Providing deal responses is voluntary. Remember, you can always choose not to review or respond to any given deal that is posted.

2. How does investorflow.org use the information we collect?

Your deal responses are managed by the deal post creator, and we treat that information as private to the deal post creator. Please contact the deal post creator directly to understand how they will use your deal responses. Some deal post creators may provide you with a privacy policy or notice at the time you review their deal and we encourage you to review that to understand how the deal post creator will handle your responses. We also use the information we collect from you (including usage data, device data, referral data and information from page tags) to manage and improve our services, and for research purposes.

3. With whom do we share or disclose your information?

We disclose:

  • Your deal responses to deal post creators. We host deal posts for deal post creators, but they are really the primary recipient of deal response data. Anything you expressly disclose in your deal post responses will, naturally, be provided to them. Please contact the deal post creator directly to understand how they might share your deal post responses.

4. What are your rights to your information?

  • Contact the deal post creator to access and correct your deal post responses. Because we collect deal post responses on behalf of deal post creators, you will need to contact the deal post creator if you have any questions about the deal they have posted, or if you want to access, update, or delete anything in your responses. We provide deal post creators with tools to maintain the responses they collect through their deal posts. You may request access to and correction of the personal information we hold about you by contacting customer support, but in most cases investorflow.org cannot provide you with this access since deal post responses are the deal post creator’s private information and giving you access may have an unreasonable impact on the privacy of other individuals or institutions. We will respond to your request for access or correction within a reasonable time and, where reasonable and practicable to do so, we will provide access to your personal information in the manner requested by you.
  • Opt out of receiving deal posts. You may opt out of receiving email invitations to review deal posts which are sent by deal post creators via investorflow.org.

5. Security, cookies and other important information

Changes to this privacy policy. We may modify this privacy policy at any time, but if we do so, we will notify you by publishing the changes on this website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email or in another conspicuous manner reasonably designed to notify you. If, after being informed of the changes, you continue to use our services beyond the advance-notice period, you will be considered as having expressly consented to the changes in our privacy policy. If you disagree with the terms of this privacy policy or any updated privacy policy, you may close your account (if you have one) at any time or not respond to a deal post.

  • Security. We intend to make details about investorflow.org’s security practices available in a Security Statement. We are committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the Internet. If you have any questions about the security of your personal information, contact customer support.
  • Data locations. Our servers are based in the United States, so your personal information will be hosted and processed by us in the United States.
  • Cookies. We and our partners use cookies and similar technologies on our websites. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. We use cookies and similar technologies for several reasons:
    • To make our site easier to use. If you use the “Remember me” feature when you sign into your account, we may store your username in a cookie to make it quicker for you to sign in whenever you return to investorflow.org.
    • For security reasons. We use cookies to authenticate your identity, such as confirming whether you are currently logged into investorflow.org.
    • To provide you with personalized content. We may store user preferences, such as your default language, in cookies to personalize the content you see.
    • To improve our services. We use cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services and optimize the content we display to users.
    • Google Analytics. In addition to the above, we have implemented on our websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.
  • We don’t believe cookies are sinister, but you can still choose to remove or disable cookies via your browser. Refer to your web browser’s configuration documentation to learn how to do this. Please note that doing this may adversely impact your ability to use our services. Enabling cookies ensures a smoother experience when using our websites. To manage flash cookies, click here. By using our websites and agreeing to this privacy policy, you expressly consent to the use of cookies as described in this policy.
  • Blogs and Forums. Our websites may offer publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We’re not responsible for any personal information you choose to submit in these areas of our site. To request removal of your personal information from our blog or community forum, contact customer support. In some cases, we may not be able to fulfill your request and we will let you know why. Commenting systems on our blogs are managed by a third party application that may require you to register to post a comment. Please review that application’s privacy policy to learn how the third party uses your information.
  • Online Tracking. We currently do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our websites or use our services (unless otherwise stated in a service-specific privacy statement).
  • Social Media Features. Our websites may include social media features or widgets, such as the Facebook Like button. Use of these features may allow them to collect your IP address, detect which page you are visiting on our site, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the third party providing it.
  • Safety of Minors and COPPA. Our services are not intended for and may not be used by minors. “Minors” are individuals under the age of majority in their place of residence (or under 13 in the United States). investorflow.org does not knowingly collect personal data from minors or allow them to register. If it comes to our attention that we have collected personal data from a minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
  • English version controls. Non-English translations of this privacy policy may be provided for convenience. In the event of any ambiguity or conflict between translations, the English version is authoritative.

6. Additional information for European Union users

  • “Personal data”. For users located in the EU, references to “personal information” in this policy are equivalent to what is commonly referred to as “personal data” in the EU.
  • About IP addresses. Our servers record the incoming IP addresses of visitors to our websites (whether or not the visitor has an investorflow.org account) and store the IP addresses in log files. We use these log files for purposes such as system administration and maintenance, record keeping, tracking referring web sites, inferring your location, and security purposes (e.g. controlling abuse, spam and DDOS attacks). We also store IP addresses along with certain actions you take on our system. By agreeing to this privacy policy, you expressly consent to investorflow.org using your IP address for the foregoing purposes. If you wish to opt out from the foregoing consent to use your IP address, you must cancel your account (if you have one) or not respond to a deal post if invited to do so.
  • Data controller. investorflow.org is the data controller for registration, billing and other account information that we collect from users in the EU. However, the data controller for deal post data is the deal post creator. The deal post creator determines how their deal posts and responses are used and disclosed. investorflow.org only processes such deal response data in accordance with the instructions and permissions (including those given under this privacy policy) that may be selected by the deal post creator when they create and administer their deal posts.
  • Accessing and correcting your personal data. You have the right to access and correct the personal information that investorflow.org holds about you. This right may be exercised by contacting customer support.

Consents. By clicking “I Agree” or any other button indicating your acceptance of this privacy policy, you expressly consent to the following:

  • You consent to the collection, use, disclosure and processing of your personal data in the manner described in this privacy policy, including our procedures relating to cookies, IP addresses and log files.
  • Our servers are based in the United States, so your personal data will be primarily processed by us in the United States. You consent to the transfer and processing of your personal data in the United States by investorflow.org and in the data locations identified above by our various affiliates and service providers.
  • You consent and agree that we may transfer your data to data processors located in countries, including the United States, which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area. Your consent is voluntary, and you may revoke your consent by opting out at any time. Please note that if you opt-out, we may no longer be able to provide you our services.
  • You consent to us sharing your personal data with relevant persons working for service providers who assist us to provide our services.
  • If you have enabled cookies on your web browser, you consent to our use of cookies as described in this privacy policy.

7. Additional information for Brazilian users

  • The personal information collected, stored, used and/or processed by investorflow.org, as described in this privacy policy, are collected, stored, used and/or processed in accordance with Brazilian Law No. 12,965/2014. By clicking “I Agree” or any other button indicating your acceptance of this privacy policy, you expressly consent to the collection, use, storage and processing of your personal information by investorflow.org as described.

8. Additional information for Australian users

  • The personal information collected by us on behalf of a deal post creator may include sensitive information. We will only use sensitive information for the purpose of storing and processing it on behalf of the deal post creator. Sensitive information is defined in the Privacy Act 1988 (Cth) and includes information about you such as racial or ethnic origin, religious beliefs, political affiliation, sexual preferences and criminal records, as well as health and genetic information about you.
  • If you are dissatisfied with our handling of your complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (OAIC) by contacting the OAIC using the methods listed on their website at http://www.oaic.gov.au. Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.

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