ImpactRaise, LLC. d/b/a ImpactRaise.com (“ImpactRaise,” “us,” “our” or “we”) is an intermediary technology platform (“Platform” or “Site”) that permits prospective investors to independently search and invest in securities offerings on the Site. By accessing the Site or using the services, website, applications and software provided through or in connection with the Site, including through a mobile device (the "Service") in any manner, you become a ImpactRaise user (“User”). You acknowledge that ImpactRaise Crowdfunding is a not a broker-dealer or investment adviser. IMPACTRAISE DOES NOT PROVIDE INVESTMENT ADVICE OR MAKE RECOMMENDATIONS. As explained below, we collect information from users (“you”, “your”, or “User”) in various ways when you interact with our Site.
Collection of Information
We may also collect and store information, which could include Non-Personally Identifiable Information or Personally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches. However, not all Non-Personally Identifiable Information and Personally Identifiable Information is stored. We may use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the Site. Google Analytics collects information including, but not limited to, the time of each of your visits to the Site, whether you have visited the Site before, what website referred you to the Site, and what pages you viewed on the Site.
Use of Information
ImpactRaise will use information that you provide consistent with this Privacy Notice. ImpactRaise will use information that you provide to us, including Non-Personally Identifiable Information or Personally Identifiable Information, to better serve you and enhance your experience with this Site, among other things. This may include having to modify or copy such Non-Personally Identifiable Information or Personally Identifiable Information, or other information such as images or textual content you provide, in order to provide you with a seamless and enjoyable experience. To this end, you consent to our use and disclosure of any information submitted to or collected by us via your use of this Site, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information unless as provided by law. mpactRaise may use Non-Personally Identifiable Information and Personally Identifiable Information: (1) to market our products and services to you; (2) to provide services and products requested by you; (3) to provide targeted advertisements and messages on our Site to you or other users of our Site; (4) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our Site and other services; (5) to conduct research and analyze data to improve our products, services, and Site; (6) to deliver special offers, updates, newsletters, customer service, and service announcements to you and other users; (7) to verify User information; (8) to comply with any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members; (9) to protect our Site or its Users; (10) to engage in any other lawful business activities that are consistent with the foregoing; and (12) as required by or to comply with law or our Company policies or to protect us from legal liability. We may provide any of these services through third parties, which may necessitate sharing Non-Personally Identifiable Information or Personally Identifiable Information with them.
ImpactRaise may make your information, including Non-Personally Identifiable Information or Personally Identifiable Information, available on its Site and visible to other Users of or visitors to the Site. For instance, subject to certain preferences and permissions as to visibility you will be allowed to make, information you provide about yourself in response to questionnaires on our Site may be made available to others such as information concerning your status as an accredited investor. As such, other Users of our Site may be able to personally identify you based on your information made available on our Site.
As a further example, if you utilize Third Party Services to log into our Site, other Users to whom you may be connected through such Third-Party Service may be able to view or follow information about you, including Non-Personally Identifiable Information or Personally Identifiable Information, on our Site. ImpactRaise may also employ or contract with other third-party partners, companies, or individuals to perform certain functions or services on its behalf.
Examples of these services from such third parties, companies, or individuals, may include ID verification, electronic document signing, payment storing and processing, sending postal mail and email, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third-party partners, companies, or individuals may have access to your information, including Non-Personally Identifiable Information or Personally Identifiable Information, needed to perform their functions or services, and may not use it for other purposes. ImpactRaise may also use and disclose Personally Identifiable Information and Non-Personally Identifiable Information to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business; to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Site or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of ImpactRaise’s business or assets.
Any successor in interest to our business would acquire the information we maintain, including Personally Identifiable Information, and may alter the terms of this Privacy Notice. Except as identified here and subject to user’s ability to opt-out as provided by Regulation S-P, ImpactRaise does not and will not sell any of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to any third party for purposes of advertising, soliciting, or telemarketing. ImpactRaise may provide Personally Identifiable Information, including your name, email address, and the date and company of any investment to certain third parties that have referred issuers and investors to ImpactRaise, or to certain Issuers, including but not limited to issuers in which you have expressed interest. ImpactRaise may also be required to disclose your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to other companies or entities if ImpactRaise may be sold or is sold to another company or entity. In that case, your information, including Non-Personally Identifiable Information or Personally Identifiable Information, may be sold or transferred to such acquiring company or entity.
Third Party Sites and Services
The Site contains links to other websites and services not maintained by ImpactRaise. In addition, other websites and services may also reference or link to the Site. We encourage you to be aware when you enter or leave our Site, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of other websites or services.
The Site permits Users to communicate with companies and other Users posting information on the Site. We may read, collect and analyze information transmitted between Users for regulatory compliance and marketing purposes. We do not guarantee that information provided by Site visitors or investors is accurate or complete. ImpactRaise assumes no liability or responsibility for any errors or omissions in the content of its Site.
How can I opt-out of certain communications?
We may at times send you email communications with information, marketing or promotional materials. If you prefer not to receive such emails from us, you may unsubscribe completely by contacting us at this email: email@example.com. Please note that opt-out requests may take up to five (7) business days to process. Please also note that at times we may need to send you transactional email communications such as service or termination announcements or payment confirmations which are communications from which you will be unable to opt-out. To unsubscribe from a third party’s communications, contact that third party directly or follow the instructions to unsubscribe in the applicable marketing e-mail. You will be able to modify the information concerning your account by visiting your profile page and editing any information you wish to change.
You will be able to view and change your email address, password, financial information, contact information, or other login information by visiting your account’s settings page subject to our Site policy. If you wish to suspend your account or need help modifying account information, please contact us through the contact form by clicking on the lower right question mark icon and selecting contact us, chat feature, or by submitting a question through the embedded “help” button.
We may require up to five business days to process such requests. Through your account settings you will be able to set certain preferences and permissions regarding the visibility of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to others. You may stop or restrict the placement of ImpactRaise cookies, Google cookies and third-party cookies on your computer by adjusting your web browser preferences or a “Do Not Track” setting in your web browser. If you do so, you may still use our Site, but this may interfere with some of our Site’s functionality. You may also clear cookies from your computer via your web browser settings. We are not responsible for removing your Personally Identifiable Information from the lists of any Third-Party Services or other third-party partner who has previously been provided your information in accordance with this agreement.
Should you ask us not to sell your information or wish to delete your information to the extent permitted by FINRA, the SEC, or otherwise permitted by law (we have strict data retention rules for customer information and transactions), please email us at firstname.lastname@example.org or chat us on our Discord.
We use commercially reasonable administrative, technical, personnel, and physical security measures designed to secure access to Personally Identifiable Information in our possession, but despite these measures, we cannot guarantee perfect or complete security of networks, servers and databases that we operate or that are operated on our behalf. Personally Identifiable Information is also stored with third parties who also have represented that they use reasonable security measures to secure access to Personally Identifiable Information, but we will not assume responsibility for the failure of any third party to safeguard Personally Identifiable Information, whether the loss or unauthorized access is inadvertent or otherwise.
Changes to this Privacy Notice
We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. Any changes or updates will be effective immediately upon posting to our Site. You should review this Privacy Notice regularly for changes and can determine if changes have been made by checking the Effective Date below. Your continued use of our Site following the posting of any changes to this Privacy Notice means you accept such changes.
Applicable Law and Jurisdiction
The Site is maintained in the United States of America. By accessing the Site, you consent to and authorize the export of Personally Identifiable Information to the United States of America and its storage and use as specified in this Privacy Notice. This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of California applicable to contracts deemed to be made within such state, without regard to choose of law or conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard either in the California state courts located in Los Angeles, California, or the federal district court of California located in Los Angeles County, California. You consent to the in-persona jurisdiction and venue of such courts.
YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.
Under California Civil Code Section 1798.83, California consumers who have business relationships with us may choose to opt out of our sharing their personal information with third parties for direct marketing purposes. If you are a California consumer and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your personal information to third parties for the direct marketing purposes, please contact us at email@example.com. Alternatively, you may send a written request to the following address:
ATTN: PRIVACY OFFICE
201 S Division St. Suite 400
Ann Arbor, MI 48104
Information for California consumers (California Consumer Privacy Act)
Collection of Information
We collect and retain the following categories of personal information, which is necessary information for us to comply with regulations governing the insurance industry and the issuance of insurance policies. We also collect personal information from our California-based employees, as required to comply with federal, state and local laws governing employers, and to fulfill our legal obligations as an employer. This personal information may include any of the following categories of personal information: (1) your real name, postal address, telephone number, unique personal identifier, email address, Social Security number, and/or similar identifiers; (2) commercial information, including investment services provided; (3) professional or employment-related information; and (4) educational information from our employees. We may collect such categories of personal information about you from: your completion of an application to make an investment with us or other forms; your transaction history and other experience with us and other companies; and in the case of an employee, from an application for employment, curriculum vitae or bio, or from a consumer reporting agency. All such personal information is used to comply with federal, state and local laws, and any SEC, FINRA or similar regulations governing our business, and for the business purpose of complying with laws governing the employment of persons who are our employees, and to effectively recruit and manage our company workforce.
Your Right to Know About Personal Information Collected, Used, Disclosed, and to Request Deletion
If you are a California consumer, upon our receipt of a verifiable request from you, you can obtain access to the personal information about you which we have collected, used, or disclosed. You may also request deletion of your personal information that is collected and maintained by us, as provided by law. To submit a verifiable consumer request to know what personal information we may have collected, used, disclosed, or to request deletion of personal information, you may email firstname.lastname@example.org. For existing account holders, you may be asked to verify your identify through the existing authentication procedures of your account, and we may re-authenticate you to verify your identity. For non-account holders, we will verify a consumer’s identity by matching at least two or three consumer-provided data points with data points that we maintain, depending on the sensitivity of the information involved.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You have a right not to receive discriminatory treatment from us for the exercise of any of your privacy rights conferred by the “CCPA”.
As a California consumer, you can designate an authorized agent to make a request under the CCPA on your behalf by your signed authorization. To do so, please write to us at the address provided below, providing your full name and address, the name and address of your authorized agent, the agent’s contact information, specifying your relationship with the authorized agent, the purpose for which you are designating the authorized agent, and provide your signed authorization. You may revoke the authority of that agent at any time by contacting us in writing at the address below.
Consumers with Disabilities
Any consumers with a disability may contact us or have an authorized agent contact us by calling our customer service department by emailing email@example.com.
Contact for More Information
For questions or concerns about our privacy policies and practices, or wish to request our policy in an alternative format please contact us at firstname.lastname@example.org Alternatively, you may send a written request to the following address:
ATTN: HELPDESK – PRIVACY
201 S Division St. Suite 400
Ann Arbor, MI 48104
(Last Updated: July 9, 2021)