Last updated: [DATE TO BE CONFIRMED]
This Privacy Policy explains how RaiseWise USA, Inc. ("RaiseWise", "we", "us") collects, uses and shares information when you use the RaiseWise.us website and platform. By using RaiseWise.us, you agree to the collection and use of information as described in this policy.
Information we collect and information you provide to us
We receive information about you when you choose to provide it, for example when you register and create a profile on RaiseWise.us: your name, address, phone number, email address, photo, Social Security number, date of birth, net worth, income, accredited investor status, biography and company page, if any. If you choose to invest in a company through the RaiseWise portal, we collect payment information from you, such as bank account and card details, and we may also collect information verifying your income. Please note that we do not store your full payment card information, but we may store other financial information. If you add an investment entity to your profile, we also collect information about that entity.
If you want to launch a fundraising campaign for your company on the RaiseWise platform, we collect information about you and your company, your offering terms and payment information.
We also collect information when you post questions or comments on RaiseWise, send or receive direct messages from other users, or contact us by email, phone or social media.
When you visit the RaiseWise website
We automatically collect certain information when you use our website, including information about your interaction with it: the actions you take, the pages or other content you view or interact with, the date and time of your visits, and the technology you use, such as your IP address, system information, browser and device type, and language.
Information from other sources
To provide the services available on the RaiseWise platform, including verifying your identity and other information you give us, we also collect information about our users from third parties and combine it with other information we receive from our users.
Third-party services
If you register through, or otherwise grant access to, a third-party social network or authentication service that we may make available (an "Integrated Service"), such as Facebook, we will collect certain personal information you previously provided to that Integrated Service (such as your name, email address, photo and other information you made available there) together with an authentication token. This information may be used to register you on RaiseWise and to enable certain features of our platform. You can revoke our access to your account on the Integrated Service at any time through your account settings. If you do so, some features may no longer be available to you on the RaiseWise portal.
Cookies and other technologies
When you visit RaiseWise, we and our service providers collect certain information using cookies and other technologies, to better understand how our users navigate our portal, learn which content is viewed, and administer and improve our website. Cookies are small text files that web servers place on users' computers to store basic information and recognize your device. We may use both session cookies, which disappear when you close your browser, and persistent cookies, which remain and may be used by your browser when you return to the website. We use Google Analytics cookies for analytics purposes; you can find information about how Google uses data from these cookies at www.google.com/policies/privacy/partners. Please check your browser settings to manage cookies. If you delete or refuse cookies, we cannot guarantee that our website will work to its full potential.
Some of our service providers, including Google, use cookies and similar technologies to display their ads elsewhere on the internet. These ads may be targeted based on the websites you previously visited and the ads you previously clicked. You can opt out of our providers' use of cookies for targeted advertising by visiting the Network Advertising Initiative opt-out page. After opting out, you will still see ads from our providers, but they will not be based on your past activity.
How we use the information we collect
We may use the information we collect to:
- Provide, improve and personalize our website and services;
- Monitor and analyze user trends and preferences;
- Process payments and investments;
- Communicate with you, including for administrative, informational and marketing purposes, and respond to your questions and requests;
- Meet the regulatory requirements that apply to the offer or sale of securities under applicable laws, rules and regulations;
- Detect, investigate and prevent fraud, money laundering and other illegal activities;
- Enforce this Privacy Policy and our other terms, and protect the rights, property and safety of RaiseWise, our users and others.
If you provide data for a specific reason, we may use it for that reason. For example, if you contact us by email, we will use that information to answer your question. You may opt out of marketing communications at any time; however, users of our services will continue to receive administrative messages necessary for our services, such as payment notifications.
How we share the information we collect
Companies you invest in. We may share your information with the companies you invest in, such as your public profile, address, email address and Social Security number, as required to complete and record your investment.
Other users and the public. Any comments or information you post or share in public areas of the RaiseWise portal, such as questions to founders, your biography or the description of your business, may be read, collected or used by other users and the public. Some of your preferences and information, for example your accredited investor status, may be visible to other users of the RaiseWise portal if you choose to make them visible. We also share your information with other users when you send or receive direct messages.
Affiliates, partners and banks. To provide the services of the RaiseWise portal, we may share your information with our affiliates, portfolio companies, investment banks, auditors and similar entities.
Service providers. We work with third-party service providers that perform services on our behalf, such as identity verification, accreditation, financial and credit verification, electronic document signing, payment processing and custody, escrow services, disbursement of funds, mail and email delivery, data analytics, fraud detection, marketing assistance and customer support. These providers only receive the information necessary to perform their services and may not use it for any other purpose.
Change of ownership. If RaiseWise USA, Inc. is involved in a merger, acquisition, reorganization, dissolution or sale of all or part of its assets, your information may be shared or transferred as part of that transaction. We will notify you by email and/or by a notice on RaiseWise.us of any change of ownership affecting your information, as well as of the choices you may have.
Other sharing. We may share information about you with third parties if we believe it is necessary to (a) comply with applicable law, regulation, legal process or government request; (b) enforce our agreements, policies or terms of service; (c) protect the property, rights and safety of RaiseWise, our users and the public; (d) respond to an emergency where we believe in good faith that sharing information may prevent death or serious bodily harm; or (e) investigate and defend ourselves against third-party claims or allegations.
We do not sell your personal information to third parties for marketing, telemarketing or solicitation purposes.
Messages, blog and testimonials
RaiseWise.us allows users to communicate with companies and other users who post information on the funding portal. We may read, collect and analyze information exchanged between users for regulatory compliance and marketing purposes. We do not guarantee that information provided by visitors or investors of the RaiseWise.us portal is accurate or complete, and we accept no responsibility for any error or omission in content posted on the funding portal.
RaiseWise.us may offer a publicly accessible blog. Information you publish there may be read, collected and used by anyone who accesses it. To request the removal of your personal information from our blog, please contact us. In some cases we may not be able to remove your information; if so, we will let you know why.
With your consent, we may display testimonials from satisfied customers together with their name and other information. If you wish to remove your testimonial, contact us at any time.
Social media
You may log in to the RaiseWise.us portal using login services such as Facebook, Twitter or LinkedIn. These services authenticate your identity and allow you to share certain information with us, such as your name and email address, to pre-fill our registration form. The RaiseWise.us portal also includes social media features, such as the Facebook "Like" button. These features may collect your IP address and the page you are visiting on our website, and may set cookies to function properly. Your interactions with these features are governed by the privacy policy of the company providing them.
Your choices
You can update the information you provided at any time through your account settings, including your email address, password and contact information. Through your account settings, you can also choose visibility preferences for your information and hide parts of your profile from other users, the public, and search engines.
You can opt out of marketing emails at any time by clicking "unsubscribe" in the emails you receive from us or by updating your communication preferences in your account settings. Please allow up to one week for your request to be processed. You cannot opt out of important service communications.
You can block or delete cookies, including Google and other third-party cookies, through your browser settings. You can still use the RaiseWise.us portal, but some features may not work properly.
If you would like us to delete your account or your personal information from our database, please contact us. Some information may need to be retained to comply with our legal and regulatory record-keeping obligations. We are not responsible for removing your personal information from third-party sites that have previously received it.
Your privacy rights under U.S. state laws
Depending on the state where you live (for example, California), you may have additional rights regarding your personal information, such as the right to know what personal information we collect, use and disclose, the right to request deletion or correction of your personal information, and the right not to be discriminated against for exercising these rights. To exercise these rights, please contact us using the details below. We will verify your request before responding.
Security
We use reasonable efforts to protect the personally identifiable information in our possession. Our portal uses HTTPS encryption to protect data transmitted between your browser and RaiseWise.us, and we use third-party providers to securely store sensitive information such as Social Security numbers, addresses, financial information, electronic signatures and payment information. For your security, we only display the last four digits of your bank account number when confirming an investment.
However, no method of transmission over the internet or of electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee its absolute security. It is important that you protect your password against unauthorized access and log out when using a shared computer.
Do Not Track
Some browsers offer a "Do Not Track" feature. Because there is not yet an accepted standard for responding to Do Not Track signals, our website does not currently respond to them.
Children's privacy
The RaiseWise.us portal is not intended for children. No one under the age of 13 may use the website, submit personal information or receive our emails, and investing on the platform is reserved for adults. We have never knowingly collected personally identifiable information from children under 13. If you believe a minor has provided us with personal information, please report it to us immediately.
Links to other websites
The RaiseWise portal contains links to websites operated by third parties, which have their own privacy policies and are not covered by this policy. We are not responsible for the content or practices of these websites. Please read the privacy policy of every website you visit.
Communications rules for issuers (advertising and general solicitation)
Marketing plays a key role in many successful crowdfunding campaigns. However, you may not make an "offer" of securities, publicly or privately, before your offering has been filed. After that (except in the very limited cases described below), communications about the terms of your offering may only appear on the RaiseWise platform.
Your company's campaign page combines marketing materials (text, graphics, videos, images, testimonials, etc.) focused on the idea behind your company, the reasons for the offering and the intended use of the funds raised, the type of securities offered and other required legal disclosures. These materials are prepared in advance for filing and publication and generally mirror the content of your Form C. Once your Form C is filed, your campaign is launched on the RaiseWise platform. All these materials are subject to anti-fraud rules and must be prepared carefully. The RaiseWise platform also includes a communication channel (Q&A) where your company can discuss its offering with investors and prospective investors.
After launch, you may not communicate the terms of the offering outside the RaiseWise platform in any form of advertising, except through a limited form of notice called a "tombstone" notice. The terms of the offering include:
- The amount of securities offered;
- The nature of the securities;
- The price of the securities; and
- The closing date of the offering.
These rules exist to direct investors to the intermediary's platform to learn more about the terms of the offering.
Tombstone notice. A tombstone notice is simply an announcement of an offering. It may include no more than:
- A statement that your company is conducting an offering;
- The name of the funding portal;
- A link to the funding portal's platform;
- The terms of the offering;
- Your company's name;
- Your company's address, phone number and website;
- An email address of a company representative; and
- A brief description of your company's business.
You may distribute a tombstone notice in any way you wish once your offering has launched, but it may not contain any other information.
Other communications. You may continue to promote your company, as long as you do not include the terms of the offering. You can create press releases, advertising, newsletters and other publicity to help your company grow, provided they do not contain any terms of the offering. These communications may include a simple statement that your company is raising funds, with a link to your campaign on the funding portal, but may not mention the terms of the raise. Be aware that a link acts as an indirect communication of the terms presented on the linked page, so be careful about how you link to your campaign.
Processing in the United States
Personal information is stored and processed on servers and databases located in the United States, where data protection laws may differ from those of your jurisdiction. If you are located outside the United States, please be aware that by using RaiseWise.us and accepting this Privacy Policy, you consent to the transfer, storage and processing of your information in the United States.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time. Updates will be posted on this page with the date of the latest revision. If the changes materially affect your rights or obligations, we will make reasonable efforts to notify you, for example by email or by a notice when you visit the website. Your continued use of the website after changes are posted means that you accept the updated Privacy Policy.
Governing law
The RaiseWise.us portal is operated in the United States. This Privacy Policy is governed by and construed in accordance with the laws of the State of New York [TO BE CONFIRMED] and applicable U.S. federal law.
Contact us
For any question about this Privacy Policy or to exercise your rights, please contact us at:
RaiseWise USA, Inc., 347 Fifth Avenue, Suite 1402, New York, NY 10016
Email: [PRIVACY EMAIL TO BE CONFIRMED]