Your Privacy Matters

At FundPage, our fundamental philosophy is “members first.” That value powers all of the decisions we make, including how we gather and respect your personal information.

We’ve crafted the policy below to be as clear and straightforward as possible. Our aim is for you—our members—to always feel informed and empowered with respect to your privacy on FundPage.

Introduction

FundPage’s mission is to provide a unique platform to bring together all the financial professionals globally and facilitate communications between public and private investors, allowing them to share investment tips, services and products. We protect your personal information using industry-standard safeguards. We may share your information with your consent or as required by law as detailed in this policy, and we will always let you know when we make significant changes to this Privacy Policy.

Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, and find business opportunities. To achieve our mission, we make services available through our website to help you, your connections, and millions of other professionals meet, exchange ideas, learn and find financial products and services.

Maintaining your trust is our top priority, so we adhere to the following principles to protect your privacy:

We may modify this Privacy Policy from time to time, and if we make material changes to it, we will provide notice through our website, apps, or other services (“FundPage” or “Service”) or by other means so that you may review the changes before you continue to use FundPage. If you object to any changes, you may close your account. Continuing to use FundPage after we publish or communicate a notice about any changes to this Privacy Policy means that you are consenting to the changes.

1. What information we collect

1.1. Data Controllers

Our Privacy Policy applies to anyone with a FundPage account. FundPage Inc. controls your information. If you have any concern about providing information to us or having such information displayed on the FundPage services or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a Member of FundPage or visit our website. If you have already registered, you should close your account. We collect your personal information in the following ways:

1.2. Registration

When you create an account with us, you provide us with information (including your name, email address, and password) that we use to offer you a personalized, relevant experience on FundPage. To create an account on FundPage, you must provide us with at least your name, email address, and a password. You can choose to provide further information about yourself during the registration process (for example, your gender and location). We use this additional information to provide you with more customized services like language- specific profile pages, updates, and content, more relevant financial services and products. You understand that, by creating an account, FundPage and others will be able to identify you by your FundPage profile, and you allow FundPage to use this information in accordance with this Privacy Policy and our User Agreement. We may also ask for your credit card details if you purchase certain FundPage services.

1.3. Profile Information

You can add professional details – like your job title, qualification, and skills – to your profile. A complete profile helps you be found by other people for opportunities. It also means we can show you relevant ads and content.

After you create an account, you may choose to provide additional information on your FundPage profile, such as descriptions of your skills, professional experience, and educational background. You can list honors, awards, professional affiliations. Providing additional information enables you to derive more benefit from FundPage by providing you with more relevant services and products; find other professionals, opportunities, and information; and help investors find you. It also enables us to serve you ads and other relevant content on and off FundPage.

1.4. Address Book, FundPage Contacts, and Other Services That Sync with FundPage

We collect information when you sync non-FundPage content – like your email address book, mobile device contacts, or calendar – with your account. We use this information to improve your experience and allow you and your network to be better connected. You can remove your address book and any other synced information whenever you'd like.

You may use the FundPage contacts importer to upload individual contacts or your entire address book into FundPage. FundPage stores this information and uses it to help you manage it with “FundPage Contacts,” which can be your primary resource for storing, organizing, and utilizing your contact information. We also use this information to enhance your FundPage experience by helping you to grow your network by: identifying your contacts already on FundPage; providing a template to send invitations to your contacts that have not registered with FundPage; suggesting financial products; and suggesting people you may know but who may not be in your FundPage Contacts. FundPage may also use this information to show you and other FundPage members that you share the same uploaded contacts who may or may not be FundPage members. Please note that when you send an invitation to connect to another individual (a “connection”), that person will have access to your email address because it is displayed in the invitation. FundPage will also remind you of pending invitations. Your FundPage connections will also have access to your email address.

FundPage makes other tools available to sync information with FundPage, and may also develop additional features that allow members to use their FundPage account in conjunction with other third-party services.

Another example are software tools that allow you to see FundPage and other public social media information about the people you email and leverage FundPage to help you gain insights from and grow your network. If you grant these products (mobile applications or other FundPage applications that sync external email services) permission to access your email accounts, they will access your email header information in order to match it to FundPage and other public social media profiles. FundPage’s products that sync with external email services will also temporarily cache message content for performance reasons; however, the cached message content will be temporarily cached in a way that is unreadable by FundPage and its service providers.

Any information that you upload or sync with FundPage is covered by the User Agreement and this Privacy Policy. You can remove your information at your convenience using the features FundPage makes available or in accordance with Section 3. You can remove your address book and any other synced information at any time.

1.5. Customer Service

When you contact our Help Center, we collect information to respond to your questions and better serve you. When you contact FundPage’s Help Center, we collect information that helps us categorize your question, respond to it, and, if applicable, investigate any breach of our User Agreement or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you.

1.6. Using the FundPage Site and Applications

We collect information when you visit FundPage, use our mobile applications, and interact with advertising on FundPage.

We collect information when you use the FundPage website, FundPage applications, and FundPage platform technology (such as “Share on FundPage” plugins for publishers). For example, we collect information when you view or click on funds, import your address book, join and participate in groups, participate in polls, install a FundPage mobile application, and like financial products on FundPage.

1.7. Using Third-Party Services and Visiting Third-Party Sites

We collect information when you use your FundPage account to sign in to other sites or services, and when you view web pages that include FundPage plugins.

We receive information when you use your FundPage account to log in to a third-party website or application. Also, when you visit a third-party site that embeds FundPage professional plugins we receive information that those pages have loaded in your web browser. If you are logged in as a FundPage Member when you visit sites with FundPage plugins, we use this information to recommend tailored content to you. FundPage will use this information to personalize the FundPage-provided functionality on third-party sites, including providing you insights from your FundPage network and allowing you to share information with your network. FundPage’s retention of this data is addressed in Section 3.2. We do not use this information for advertising. FundPage may provide reports containing aggregated impression information to companies hosting FundPage plugins and similar technologies to help them measure FundPage-generated traffic to their websites.

1.8. Cookies

We use cookies to help personalize your FundPage experience and show you relevant financial products.

We use cookies and similar technologies, including mobile device identifiers, to help us recognize you, improve

your FundPage experience, increase security, measure use of our Services, and serve advertising. You can control cookies through your browser settings and other tools. By visiting FundPage, you consent to the placement of cookies and beacons in your browser in accordance with this Privacy Policy.

1.9. Advertising Technologies and Web Beacons

We target financial products ads to you on and off FundPage, based on information you included in your profile and your use of FundPage.

We target ads to Members both on and off FundPage through a variety of ad networks and ad exchanges, using:

FundPage may show you sponsored content in your Network Update Stream (NUS), which will be designated as sponsored content and will behave like other NUS updates. If you take social action (for example, if you “like or “comment” on the sponsored content), your action will be seen by your network and other FundPage Members who are shown the sponsored content after you have acted on it.

1.10. Log Files, IP Addresses, and Information About Your Computer and Mobile Device

We collect information from the devices and networks that you use to access FundPage. This information helps us improve and secure our Services.

When you visit or leave FundPage by clicking a hyperlink or view a plugin on a third-party site, we automatically receive the URL of the site from which you came or the one to which you are directed. Also, advertisers receive the URL of the page that you are on when you click an ad on FundPage. We also receive the internet protocol (“IP”) address of your computer or the proxy server that you use to access the web, your computer operating system details, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing FundPage using a mobile device), and the name of your ISP or your mobile carrier. We may also receive location data passed to us from third-party services or GPS-enabled devices that you have set up, which we use to show you local information (for example, weather information) on our iPad application.

1.11. Other

We are constantly innovating to improve our Services, which means we may create new ways to collect information on the Service. FundPage is a dynamic, innovative environment, which means we are always seeking to improve the services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information.

2. How we use your personal information

At FundPage, we take pride in our mantra of “Members first,” which means that above all else we strive to use your information to provide you world-class services in a professional and trustworthy manner.

2.1. Consent to FundPage Processing Information About You

When you join FundPage, you acknowledge that information you provide on your profile can be seen by others and used by us as described in this Privacy Policy and our User Agreement.

The personal information you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name may reveal your gender). By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of FundPage’s User Agreement and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying information to us, including any information deemed “sensitive” by applicable law, is entirely voluntary on your part. You have the right to withdraw or modify your consent to FundPage’s collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your Settings, changing your profile, or by closing your account.

2.2. FundPage Communications

We communicate with you using FundPage messaging, email, and other ways available to us. We may send you messages relating to the availability of the Services, security, or other service-related issues. We also may send promotional FundPageMail messages to your FundPage inbox. You can change your email settings at any time.

We communicate with you through email, notices posted on the FundPage website, messages to your FundPage inbox, and other means available through the Service, including mobile text messages and push notifications. Examples of these messages include: (1) welcome and engagement messages - when you register on FundPage, we may send you a series of emails to inform you about how to best use FundPage as well as new features; (2) service messages – these will cover service availability, security, and other issues about the functioning of FundPage; (3) promotional messages – these include both email and FundPage Mail messages (FundPage Mail messages are only delivered to your FundPage inbox), and may contain promotional information directly or on behalf of our partners. These messages will be sent to you based on your profile information and messaging preferences. FundPage tracks the open rate of your FundPage Mails to provide your FundPage Mail acceptance score. You may change your email and contact preferences at any time by signing into your account and changing your email settings. You can also opt out of promotional messages by sending a request to FundPage Help Center. Please be aware that you cannot opt out of receiving service messages from FundPage.

2.3. User Communications

With certain communications you send on FundPage, the recipient can see your name, email address, and some network information.

Many communications that you initiate through FundPage (for example, an invitation sent to a non-Member) will list your name and primary email address in the header of the message. Messages you initiate may also provide the recipient with aggregate information about your network (for example, how many people are in your network). Other communications that you initiate through the Services, like a request for an introduction, will list your name as the initiator but will not include your personal email address contact information. Once you have connected with an individual, regardless of who sent the invitation, your contact information will be shared with that individual.

2.4. Customized Content

We use the information you provide on your profile to customize your experience on FundPage.

We use information that you provide to us to customize your experience and the experiences of others on FundPage. For example, when you sign in to your account, we may display the names of new funds you may interested base on your setting or recent updates from your connections and financial products and service you may interested. We also use aggregated information from your network to show you content, such as funds, IA and news relevant to you.

2.5. Sharing Information with Affiliates

We may share your personal information with our FundPage affiliates outside of the FundPage entity that is your data controller (for example, FundPage Inc. may share your information with other FundPage operating entities) as necessary to provide the Services. By agreeing to this Privacy Policy, you are consenting to this sharing.

2.6. Sharing Information with Third Parties

Any information you put on your profile and any content you post on FundPage may be seen by others. We don’t provide any of your non-public information (like your email address) to third parties without your consent, unless required by law, or as described in Sections 2.6 and 2.14 of this Policy. Other people may find your FundPage profile information through search engines, or use services like Twitter in conjunction with your FundPage account.

FundPage offers a “public profile” feature that allows Members to publish portions of their FundPage profile to the public Internet. This public profile will be indexed and displayed through public search engines when someone searches for your name. Third-party search engines may not automatically update their caches, which may contain old public profile information. Unless you delete it, your profile on FundPage is always viewable on the FundPage Services.

We do not rent or sell personal information that you have not posted on FundPage, except as described in this Privacy Policy. We will not disclose personal information that is not published to your profile or generated through engagement with other FundPage services without your consent or to carry out your instructions (for example, to process payment information) unless FundPage has a good faith belief that disclosure is permitted by law or is reasonably necessary to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Privacy Policy or our User Agreement; (3) respond to claims of a violation of the rights of third parties; (4) respond to Member service inquiries; or (5) protect the rights, property, or safety of FundPage, our Members, or the public. See Section 2.14 for additional details about FundPage’s compliance with legal requests for information.

FundPage supports middleware providers that offer archiving solutions to firms subject to financial services regulation, which, with your permission, facilitate the archiving of your communications and other FundPage activity by a third party for compliance purposes. Content distributed through FundPage’s sharing features and third-party integrations may result in displaying some of your personal information outside of FundPage. Further, FundPage allows third parties to look-up profile information (subject to your privacy settings) using your email address or first and last name information through its profile API (see Section 2.7. below).

Third parties (for example, your email provider) may give you the option to upload certain information in your FundPage contacts onto their own service. If you choose to share your FundPage contacts, you will be granting your third party provider the right to store, access, disclose and use your FundPage contacts in the ways described in such third party's terms and privacy policy.

2.7. Developers Using FundPage Platform Services

We work with developers to build Platform Applications using FundPage’s developer tools. Whether you use Platform Applications is up to you. If you have given a Platform Application access to your FundPage account, you can revoke that permission anytime. Also, you can opt out of providing information to developers through your connections.

We collaborate with and allow third parties to use FundPage’s developer platform to offer services and functionality in conjunction with FundPage. These third-party developers have either negotiated an agreement to use FundPage platform technology or have agreed to our self-service API and Plugin terms in order to build applications (“Platform Applications”). Both the negotiated agreements and our API and Plugin terms contain restrictions on how third parties may access, store, and use the personal information you provide to FundPage. If you choose to use a Platform Application, you will be asked to confirm acceptance of the privacy policy and user agreement of the third-party developer.

2.8. Polls and Surveys

We conduct our own surveys and polls and also help third parties do this type of research. Your participation in surveys or polls is up to you. You may also opt out of getting invitations to participate in surveys.

Polls and Surveys may be conducted by FundPage, Members, or third parties. Some third parties may target advertisements to you on the results page based on your answers in the poll. FundPage or third parties may follow up with you via FundPage Mail regarding your participation. We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personal information to the third party fulfilling the incentive offer, which will be used only for the purpose of delivering incentives and verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive. Your consent to use any personally identifiable information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it.

2.9. Search

FundPage helps you search for other professionals, companies, groups, professional content, financial products and services.

You can search for Members, investment opportunities, information about financial service and products, and community content from FundPage Groups on FundPage. For example, you can find Members with particular expertise or experience, or Members that you may know from your industry or profession. You can also find content from FundPage Fund and FundPage IA. We use personal information from FundPage, including Member profiles, Groups content, and Company Pages, to inform and refine our search service.

2.10. Groups

You are responsible for any information you post on FundPage, and this content will be accessible to others. If you participate in FundPage Groups, share content on your Network Update Stream, or import a blog or other content, you should be aware that any information you choose to disclose using these services can be read, collected, and used by other Members in these forums, developers, and other third parties. FundPage is not responsible for the information you choose to submit in these forums. Some content in FundPage Groups may be public and searchable on the Internet.

2.11. Testimonials and Advertisements Placed through FundPage Ads

If you provide any testimonials about our goods or services or place advertisements through the FundPage Ads, we may post those testimonials and examples of advertisements you place in connection with our promotion of these services to third parties. Testimonials and advertisements may include your name and other personal information that you have provided. For more information about FundPage Ads, please see the FundPage Ads Terms of Use.

2.13. Compliance with Legal Process and Other Disclosures

We may disclose your personal information if compelled by law, subpoena, or other legal process, or if necessary to enforce our User Agreement.

It is possible that we may need to disclose personal information, profile information, or information about your activities as a FundPage Member when required by law, subpoena, or other legal process, or if FundPage has a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the User Agreement, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) exercise or protect the rights, property, or safety of FundPage, our Members, personnel, or others.

2.14. Disclosures to Others as the Result of a Change in Control or Sale of FundPage Corporation

If there is a change in control or sale of all or part of FundPage, we may share your information with a third party, who will have the right to use that information in line with this Privacy Policy.

We may also disclose your personal information to a third party as part of a sale of the assets of FundPage Inc, a subsidiary, or division, or as the result of a change in control of the company or one of its affiliates, or in preparation for any of these events. Any third party to which FundPage transfers or sells FundPage’s assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

3. Your Choices & Obligations

3.1. Rights to Access, Correct, or Delete Your Information, and Closing Your Account

You can change your FundPage information at any time by editing your profile, deleting content that you have posted, or by closing your account. You can also ask us for additional information we may have about your account.

You have a right to (1) access, modify, correct, or delete your personal information controlled by FundPage regarding your profile, (2) change or remove your content, and (3) close your account. You can also contact us for any account information which is not on your profile or readily accessible to you. If you close your account, your information will generally be removed from the Service within 24 hours. We generally delete closed account information and will de-personalize any logs or other backup information within 30 days of account closure, except as noted below.

Please note: Information you have shared with others (for example, through FundPage Mail, network updates, content sharing, Live Chat, or FundPage Groups) or that others have copied will be sent a copy to others via their email if the other part is an licensed financial professional for audit purpose and may also remain visible after you have closed your account or deleted the information from your own profile. FundPage Groups content associated with closed accounts will show an unknown user as the source. In addition, you may not be able to access, correct, or eliminate any information about you that other Members copied or exported out of FundPage (email sent to IA for example), because this information may not be in our control. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

3.2. Data Retention

We keep your information for as long as your account is active or as needed. For example, we may keep certain information even after you close your account if it is necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce this agreement.

We retain the personal information you provide while your account is in existence or as needed to provide you services. FundPage may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Privacy Policy and our User Agreement. We may retain personal information, for a limited period of time, if requested by law enforcement. FundPage's Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only, but we generally delete or de-personalize closed account data consistent with Section 3.1., except in the case of our plugin impression data, which we will try to de-personalize at the time of collection, but in any event, we will de-personalize within 7 days.

3.3. Your Obligations

Please respect the terms of our User Agreement, our Policies, and your fellow FundPage Members.

As a Member, you have certain obligations to other Members. Some of these obligations are imposed by applicable law and regulations and others have become commonplace in communities of like-minded Members such as FundPage:

Any violation of these guidelines or those detailed in our User Agreement or elsewhere may lead to the restriction, suspension, or termination of your account at the sole discretion of FundPage.

4. Important Information

4.1. Minimum Age

You have to meet FundPage’s minimum age requirements to create an account.

As described in Section 2.3. of the User Agreement, persons must be of Minimum Age to use FundPage.

4.2. Changes to this Privacy Policy

We will notify you when we change this Privacy Policy.

We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the Service or by some other means, such as email. Please review the changes carefully. If you agree to the changes, simply continue to use our Service. If you object to any of the changes to our terms and you no longer wish to use FundPage, you may close your account. Unless stated otherwise, our current Privacy Policy applies to all information that FundPage has about you and your account. Using FundPage after a notice of changes has been communicated to you or published on our Service shall constitute consent to the changed terms or practices.

4.3. Security

We take privacy and security seriously and have enabled HTTPS access to our site, in addition to existing SSL access over mobile devices. Also, please know that the Internet is not a secure environment, so be careful and select strong passwords.

We have implemented security safeguards designed to protect the personal information that you provide in accordance with industry standards. Access to your data on FundPage is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the FundPage Services. We also offer secure https access to the website. To protect any data you store on our servers, we also regularly monitor our system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the Internet is not a 100% secure environment, we cannot ensure or warrant the security of any information that you transmit to FundPage. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other FundPage Members are not encrypted, and we strongly advise you not to communicate any confidential information through these means. Please help keep your account safe by using a strong password.

How To Contact Us

If you have questions or comments about this Privacy Policy, please contact us by email at: Support@FundPage.com