Privacy Policy Updated February 27th, 2015

Summary of Major Changes

We clarified that Personal Data is information that identifies you and that can be used alone to contact you online or offline. Personal Data may be supplemented or tied with other information, including non-personal or anonymous information and information that we receive from third parties.

Non-personal information is information that alone cannot be used to identify or contact you, such as your demographic information and information about your computer. We may use and share non-personal information for purposes such as improving our products and services and providing services to you.

We may receive information from third parties that we use to supplement Personal Data and non-personal information. Such information from third parties includes demographic information, information provided by social networking sites, and information about you from other CircleUp users (e.g., contact information).

You may be required to create an account to use certain services on the Site. If you create a CircleUp account using, or to connect to CircleUp through, a social networking site, that site may share certain Personal Data and non-personal information with us that we may use to create the account and for other purposes described in the Privacy Policy.

We use various technologies on the Site to provide Services, offer you ads, and for other purposes. Such technologies include clear GIFs, tracking pixels, cookies, web beacons, and certain third party analytics and ad serving technologies. The third party analytics and advertising companies we use may also collect information from the Site using these technologies and combine it with other information they have, such as information they have collected from other websites, and use and share it in accordance with their own privacy policies.

We may use and share your Personal Data and non-personal information to improve the Site, personalize the Site, enforce our Terms of Service, investigate activities that violate our policies, and comply with law, among other uses. We may also share your Personal Data and non-personal information with our third party contractors, including contractors who provide email delivery, products, advertising, analytics and other services. You will be notified before your Personal Data is collected by any third party that is not our agent or contractor.

The Site offers certain forums that are publicly accessible, such as blogs and message boards. Please be aware that any information you provide in these forums (including Personal Data) may be read, collected, and used by others who access them, and could be used to send you unsolicited messages. We are not responsible for the information you choose to make public in any of these forums. You may request removal of your personal information from our blog, but we may be unable to do so in some cases.

We will retain your information for as long as your account is active or as needed to provide you Services, unless a longer retention period is required or permitted by law.

You may opt out of targeted advertising delivered by the National Advertising Initiative (NAI) member ad networks by visiting www.networkadvertising.org.

You may opt-in to allow CircleUp to share your Personal Data with companies and organizations that provide products or services that may be of interest to you. To opt out of further communications from these partners after your information has been shared, please contact that partner directly.

  1. Our Commitment to Privacy

    At CircleUp, our most important asset is our relationship with you. We are required by law to ask for certain information in order to perform our services for you, but we are committed to protecting your personal and financial information. This Privacy Policy describes the treatment of information provided on the sites where this Privacy Policy is posted. It also describes the treatment of information provided by you on applications that we make available on third-party sites or platforms if disclosed to you in connection with the use of such applications. This Privacy Policy also describes the choices available to you regarding our use of your information and how you can access and update this information.

  2. Our Policy

    Welcome to the web site www.circleup.com (the "Site") owned and operated by CircleUp Network, Inc. (Henceforward "CircleUp," "we," "us," and/or "our"). This Site has been created to provide information about our company and its financial matchmaking services (the "Services") to all users of the Site or Service, including entrepreneurs ("Issuers") and Accredited Investors, as defined by SEC Regulation D Rule 501 ("Investors"), who in any way use the Site or any Service provided by CircleUp (in each case, a "User"). This Privacy Policy sets forth CircleUp's policy with respect to information, including personally identifiable information ("Personal Data"), and other information that is collected from Site visitors and users of the Services. If you have questions or complaints regarding our privacy policy or practices, please contact us at info@circleup.com.

    IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE ANY CIRCLEUP SITE OR SERVICE. If we change our Privacy Policy, we will post those changes to this Privacy Policy, the CircleUp homepage, or other locations so that you are aware of the information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material or significant changes to this policy, we will notify you here, by email, or by means of a notice on our homepage prior to the changes taking effect. Your continued use of our products and services will signify your acceptance of the changes to our Privacy Policy.

  3. Types of Information We Collect

    Personal Data That You Provide Through the Site:  Personal Data is information that identifies you and that can be used alone to contact you online or offline. We collect Personal Data from you when you voluntarily provide such information to us such as when you register for access to the Services (for example, contact information such as your name, email address, and mailing address) when you wish to use certain Services (for example financial information such as bank account numbers, your date of birth and the last four digits of you social security number), when you contact us with inquiries or respond to our marketing surveys and email campaigns, when you link to your profile on a third-party site or platform with your Account, and otherwise when you use our services where Personal Data is required for use and/or participation. When anonymous information is directly associated with Personal Data, this anonymous information is also treated as Personal Data.

    By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy and you agree that you will abide by our Terms of Service. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of CircleUp and the authorized third parties referred to herein located in the United States of America.

    Non-Personal, Anonymous, or Aggregated Data:Non-personal information, alone, cannot be used to identify or contact you. When you interact with CircleUp through the Site or Services, we receive and store certain non-personal information about you for purposes that include improving our products and services, troubleshooting bugs, providing services to you, facilitating the provision of updates, dynamically served content and product support, and communicating with you. Such information, which may be collected passively using various technologies or through other means, may include demographic information including gender, age, zip code, information about your computer, hardware, software, media, mobile device, including unique device IDs or other device identifiers, incident data, Internet Protocol (IP) address, network Media Access Control (MAC) address and connection. We may also receive information from third parties in connection with marketing and demographic studies and/or other data that we use to supplement personal information provided directly by you.

  4. How We Collect Information

    We collect information you provide to us when you request products, services or information from us, register with us, participate in forums or other activities in our sites and applications, respond to surveys or otherwise interact with us.

    In order to access additional functionality of the Site, you may be required to create an account for your use of the Service (an “Account”). You may create an Account directly via the Site or by logging into your Account with certain third party social networking sites (including Facebook and LinkedIn) via our Service. If you decide to create an Account by logging into a social networking site via our Service, we will obtain the Personal Data you have provided to the social networking site (such as your name, profile picture, email address, and other information you make publicly available via the applicable social networking site) from the account you have with such social networking site and use that information to create your Account. The information we obtain may depend on the privacy settings you have with the social networking site. We also collect other information that you provide as part of account registration and your use of the Service.

    • Internet Log Files

    As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. CircleUp may store such information itself or such information may be included in databases owned and maintained by CircleUp affiliates, agents, or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors' Internet service providers, and how our users use and interact with the Services. Also, in an ongoing effort to better understand and serve the users of the Services, CircleUp often conducts research on its customer demographics, interests, and behavior based on Personal Data and other information provided to CircleUp by Issuers and Users.

    This research may be compiled and analyzed on an aggregate basis. CircleUp may share this non-personal and aggregate data with its affiliates, agents and business partners, but this type of non-personal and aggregate information does not identify you personally. CircleUp may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.

    • Cookies

    In operating this Site, we may also use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Site gives to your browser when you access the Site. Our cookies help provide additional functionality to the Site and help us analyze Site usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Site without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site's features.

    The use of cookies by our any of our affiliates or service providers is not covered by our privacy policy. We do not have access or control over these cookies. Our partners may use session ID cookies to make it easier for you to navigate our site and use our Services.

    • Clear GIFs and Tracking Pixels

    Clear GIFs (including web bugs, beacons or tags) are small graphic images placed on a web page, web-based document, or in an email message. Clear GIFs are invisible to the user because they are small (only 1-by-1 pixel) and usually the same color as the background of the web page, document or email message. We do not use clear GIFs to collect Personal Data about you. We may, however, use clear GIFs to capture statistical usage information for our web pages, features or other elements on a web page. We correlate this information to a user to personalize user experience and for statistical analysis of user experiences on our web pages.

    We and third parties may also use tracking pixels, which allow us to advertise more efficiently by, for example, excluding our current users from certain promotional messages or identifying the source of a new installation.

    • Analytic Metric Tools and Other Technology

    CircleUp uses third party analytics technologies to collect information when you use our online services. These tools and technologies use server log files, web beacons, cookies, tracking pixels and other technologies to collect and analyze certain types of information, including cookies, IP addresses (including for purposes of determining your approximate geographic location), mobile or other hardware device ID or other device identifiers, browser types, browser language, information passed from your browser (if any), referring and exit pages, and URLs, platform type, click information, information about your media, peripheral hardware, software and/or applications installed on your machine and/or device, domain names and types, landing pages, pages viewed and the order of those pages, advertising conversion rates, the date and amount of time spent on particular pages, other internet and website usage information, and the date and time of activity on our websites, as well as unique hardware identifies such as MAC Address, mobile unique device ID (if applicable) and other similar information.

    The third party analytics companies who collect information on our sites and the in the context of our products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.

    • This Site Uses Google Analytics and AdWords

    This Site uses Google Analytics to track viewing trends and help analyze how visitors use the CircleUp Site. This information helps us to improve the CircleUp Site and the overall user experience. Google Analytics uses cookies to collect standard internet log information and visitor behavior information in an anonymous form. None of the information gathered is personally identifiable in nature without your expressed permission. This Site also uses the Google AdWords remarketing service to advertise CircleUp and CircleUp Issuers on third party websites to previous visitors of the CircleUp Site. Google AdWords remarketing will display relevant ads tailored to you by using a cookie that helps track what parts of the CircleUp Site you have viewed. Google AdWords remarketing allows us to tailor our marketing efforts to better suit your needs and display ads that are most relevant to your interests.

    You can set preferences for how Google advertises to you using the  Google Ad Preferences page. Or, you may opt out of a third party vendor's use of cookies by visiting the  Network Advertising Initiative opt out page.

    • Ad Serving Technology

    CircleUp’s websites, online or mobile products or services may employ proprietary or third party ad serving technologies that use cookies, clear GIFs, web beacons, tracking pixels or other technologies to collect information as a result of ad serving through our products or services as well as to help track results. We or third parties operating the advertisement serving technology may use information such as age and gender as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the site, online or mobile product or service and to calculate or control the number of unique and repeat views of a given ad, and/or deliver ads that may relate to your interests and measure the effectiveness of ad campaigns. We or third parties may collect data for this purpose including IP address (including for purposes of determining your approximate geographic location), device IDs, information about your software, applications and hardware, browser information (and/or information passed via your browser), hardware, machine or device make and model, advertisement(s) served, length of time an advertisement was visible, other Internet and website usage information, web pages and mobile internet sites which have been viewed by you (as well as date and time), domain type, size of the advertisement, advertisement response (if any), and angle of view. The foregoing data may be used and disclosed per this policy and the privacy policy of the company providing the ad serving technology.

    The advertising companies who deliver ads for us may combine the information collected or obtained from CircleUp with other information they have independently collected from other websites and/or other online or mobile products and services relating to your web browser’s activities across their network of websites. Many of these companies collect and use information under their own privacy policies.

    For more information about the practices of other ad serving companies that may collect information based on your interaction with ads on this site, in our mobile products, and other sites or products not owned/managed by CircleUp, or to “opt out” of targeted advertising delivered by National Advertising Initiative (NAI) member ad networks, you should visit www.networkadvertising.org.

    • Other Information Collected From Third Parties

    CircleUp may also receive other information from third parties, including in connection with the operation of our products and services as well as marketing and demographic studies that we use to supplement personal and anonymous information or provided directly by you. Some third party services such as Twitter, Facebook, and LinkedIn may also provide us with information from your accounts there with your permission.

    By connecting to CircleUp through a social network or other third party platform or services, via one of our products and/or services, you are authorizing CircleUp to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the social network or other third party platform could provide to CircleUp through the social network/third party platform Application Programming Interface (API) based on your settings on the third party social network platform. Your agreement takes place when you connect with the third party network, platform or service via our products and/or services, and/or when you connect with, “accept” or “allow” (or similar terms) one of our applications through a social network, or other third party platform or service.

    CircleUp may also collect or receive information about you from other CircleUp users who choose to upload their email and other contacts. This information will be stored by us and used primarily to help you and your friends connect.

  5. Our Use of Your Personal Data and Other Information

    CircleUp uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. We also may obtain information about you from third party sources to verify your identity so we can properly process your requests and prevent fraud. By accessing our Site and using our Services, you hereby explicitly consent that we may use your submitted and obtained Personal Information for such purposes.

    CircleUp and its subsidiaries and affiliates (the "Related Companies") may also use your Personal Data and other personally non-identifiable information collected through the Site to help us improve the content and functionality of the Site, to enforce our Terms of Service, to better understand our users, to detect, investigate and prevent activities that may violate our policies or be illegal, to personalize control and experiences on our sites and applications, and to improve the Services. CircleUp and its Related Companies may use this information to communicate with you regarding the Services or to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Note however that as a User of the Service we will send you administrative communications that are reasonably necessary to the Service. If CircleUp intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

    If you choose to use our service to refer a friend to a CircleUp product or site, we may ask you for your friend’s name and email address. In such cases, we will send your friend an email on your behalf inviting him or her to visit the site or check out our products. CircleUp retains your friend’s name and email for a short period for the sole purpose of sending this email. We do not keep or use this information for any other purpose.

  6. Our Disclosure of Your Personal Data and Other Information

    We will share personal and other information with third parties only in the ways that are described in this Privacy Policy. There may also be circumstances where you may share information on your own. You may opt-in to allow CircleUp to share your personal information with companies and organizations that provide products or services that may be of interest to you. To opt out of further communications from a marketing partner or sponsor with your information has been shared, please contact that partner or sponsor directly.

    From time to time, CircleUp employs third party contractors to collect Personal Data on our behalf to provide email delivery, products, promotional fulfillment, shipping or other services on our sites. When requesting these services, you may be asked to supply your name, mailing address, telephone number and email address to our contractors. We ask some third party contractors, such as data analytics or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and related advertising to better meet our visitors’ needs and preferences. To enrich our understanding of individual customers, we tie this information to the Personal Data you provide to us.

    When our third party agents or service providers collect and/or have access to any information other than non-personal, anonymous and/or aggregated data, CircleUp requires that they use data consistently with our stated Privacy Policy. These third parties are prohibited from using your personal information for any other purpose without your specific consent.

    You will be notified before your Personal Data is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.

    We may also access and disclose personal information, including personal communications, in connection with report abuse functions in our products and services, to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on CircleUp. Note that certain publically available information you post and communicate on our and third party sites and services is public information for which you have no expectation of privacy.

    • Testimonials

    We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name and other information. If you wish to update or delete your testimonial, please contact us at info@circleup.com

    • Public Information Including User Generated Content, Forums, Blogs, And Profiles

    Our Web site offers a publicly accessible blog. You should be aware that any information you provide in this area may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at info@circleup.com. In some cases, we may not be able to remove your Personal Data, in which case we will let you know if we are unable to do so for any reason.

    You may choose to disclose information about yourself in the course of contributing content to CircleUp or in our online forums, blogs, message boards, user “profiles” for public view or in similar forums on our sites and/or on third party sites. Information that you disclose in any of these forums is unencrypted, public information, may be accessed or recorded by CircleUp employees, and there is no expectation of privacy or confidentiality there.

    You should be aware that any Personal Data you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Data you choose to make public in any of these forums.

    Note also that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. CircleUp has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.

    If you post a video, image, or photo on one of our sites for public view should you be aware that these may be viewed, collected, copied and/or used by other users without your consent. We are not responsible for the videos, images, or photos that you choose to submit to the CircleUp site.

    There are also certain circumstances in which we may share your Personal Data and other information with certain third parties without further notice to you, as set forth below:

    Business Transfers:As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

    Related Companies:We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy.

    Agents, Consultants and Related Third Parties:CircleUp, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, ID verification, processing applications, shipping and fulfillment, and processing payments and completing transactions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These companies are authorized to use your personal information only as necessary to provide these services to us.

    Legal Requirements:CircleUp may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of CircleUp, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public against fraud or other harm, or (iv) protect against legal liability.

  7. Your Controls and Choices

    If your Personal Data changes, or if you no longer desire our service, you may correct, update, amend, delete or request deletion by making the change in your registered account settings page, by emailing us at info@circleup.comor by contacting us at the contact information listed at the bottom of this Privacy Policy. We will respond to your request as soon as commercially reasonable.

    When you sign up for our Services or newsletter(s), we will send periodic emails to you regarding the Services or to tell you about services we believe will be of interest to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at  info@circleup.com

  8. Data Security, Integrity and Retention

    The security, integrity and confidentiality of your information are important to us.We use commercially reasonable efforts to follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as bank account information) on our website, we encrypt the transmission of that information using secure socket layer technology (SSL). We also use third party ID verification to ensure our users’ true identities are validated. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We cannot assume responsibility or liability for unauthorized access to our servers and systems. We will retain your information for as long as your Account is active or as needed to provide you services unless a longer retention period is required or permitted by law. If you wish to cancel your Account or request that we no longer user your information please contact us at info@circleup.com. If you have any questions about security on our Web site, you can also contact us at  info@circleup.com as well.

  9. Exclusions

    This Privacy Policy does not apply to any Personal Data collected by CircleUp other than Personal Data collected through the Site or Services. This Privacy Policy shall not apply to any unsolicited information you provide to CircleUp through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as bulletin boards or forums (collectively, "Public Areas"), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and CircleUp shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

  10. Children’s Privacy

    CircleUp does not knowingly collect Personal Data from children under the age of thirteen. If you are under the age of thirteen, please do not submit any Personal Data 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 Data on this Site without their permission. If you have reason to believe that a child under the age of thirteen has provided Personal Data to CircleUp through this Site, please contact us, and we will endeavor to delete that information from our databases.

  11. Links to Other Web Sites

    This Privacy Policy applies only to the Site. This Site may contain links to other web sites not operated or controlled by CircleUp (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The fact that we link to a Website is not an endorsement, authorization or representation of our affiliation with that third party. If you click on a link to a third party site, including on an advertisement, you will leave the CircleUp site you are visiting and go to the site you selected. Because we cannot control the activities of third parties, we cannot accept responsibility for any use of your Personal Data by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as CircleUp. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party Website that is linked to a CircleUp site, you should consult that site’s privacy policy before providing any Personal Data.

    Members may register for other services from our site(s). Certain products and/or services available on our site are provided to you in partnership with third party(s) and may require you to disclose Personal Data in order to register for and access such products and/or services. Such products and/or services shall identify the third party partners at the point of registration. If you elect to register for such products and/or services your Personal Data will be transferred to such third party(s) and will be subject to the privacy policy and practices of such third party(s). We are not responsible for the privacy practices and policies of such third party(s) and, therefore, you should review the privacy practices and policies of such third party(s) prior to providing your Personal Data in connection with such products and/or services.

  12. Changes to this Privacy Policy

    We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

  13. California Residents: California Privacy Rights

    Under California law, California Residents who have an established business relationship with CircleUp or one of its subsidiaries may choose to opt out of CircleUp’s disclosure of Personal Data about them to third parties for direct marketing purposes. If you choose to opt out at any time after granting approval, email info@circleup.com or write to CircleUp Network Inc., 818 Mission Street, Suite 300, San Francisco, CA, 94103.

  14. Contacting CircleUp

    Please feel free to contact us if you have any questions about CircleUp's Privacy Policy or the information practices of this Site:

    CircleUp Network, Inc.

    info@circleup.com

    CircleUp Network Inc.
    818 Mission St, Suite 300
    San Francisco, CA 94103