Privacy Policy
Last updated June 11, 2021
Thank you for choosing to be part of our community at Crimson Capital. We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@crimson-capital.com.
This privacy notice applies to all information collected through our Services (which, as described above, includes our Website ), as well as, any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal Information You Provide
We use the term “Personal Information” to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to identify you. What Personal Information we collect from you depends on what Services you choose to use and how you interact with the Site:
Personal Information You Provide
We use the term “Personal Information” to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to identify you. What Personal Information we collect from you depends on what Services you choose to use and how you interact with the Site:
- Site Visitors. We have structured our Site so that, as a casual site visitor, you may come to our Site and review selected information about our Services without registering. However, if you wish to become an Investor, then we require you to provide certain additional Personal Information.
- Investors. If you choose to access our Services as an Investor, we require that you complete a registration form. An Investor is an individual who is over the age of 18 and has completed the registration process on the Site. Our registration forms will specify the information which you must provide in order to enjoy the particular features to which you wish to subscribe, which may include such items as (i) name; (ii) email address; (iii) phone number(s); (iv) mailing address; (v) social security number (for IRS tax reporting purposes); (vi) bank account number; and (vii) birth date. Our registration forms may additionally request information that you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personal Information, we will treat it in the manner specified in this Privacy Policy.
We may require each Investor to provide information designed to verify his or her identity. This information may include (i) information from a successfully completed electronic check transaction, (ii) a credit report, or (iii) other similar information designed to authenticate and confirm your identity or to otherwise comply with applicable law.
We also require each Investor to provide certain financial information. For example, we require that each Investor also provide Internal Revenue Service Form W-9 data, which includes your Social Security Number (or Taxpayer Identification Number, where applicable). We also require that Investors provide us with certain account and other payment information, such as information needed to make payments via ACH, wire, or electronic checks. Our registration process for Investors provides additional details on the types of payment information needed.
Users also may choose to upload media files such as videos, photos, text, and other content to the Site to share with Fundrise and other users. When you upload this content, we may also collect metadata associated with these media files including date, time, location and device information. Fundrise’s use of such content will be governed by our user-generated terms and conditions which are provided at the time of collection of such content.
- Location Data. We may collect your location information through our mobile applications by capturing the location (e.g. latitude/longitude) of your mobile device. If you have given the app permission to access your location, we may collect your device’s location even if you are not using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to restrict the app’s access to your location data. Geolocation data may be used to enhance the Services, for example to offer additional functionality and information regarding your location in connection with the location of Fundrise properties.
- Automatically-Collected Information Even if you do not register for an account on the Site, we may collect certain information automatically. For example, we may automatically receive and record in our system the following information:
-your internet protocol (IP) address and location;
-referrer URL;
-the type and version of your web browser;
-device identifiers including mobile advertising identifiers; and
-your operating system.
We also record page views and other general statistical and tracking information. We use this data to help us administer and operate our Site, to better understand how our users access and interact with the Site, and for security and monitoring purposes.
We may send email messages that use a “click-through URL” linked to content on our Site. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked, simply do not click text or graphic links in the email.
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
3. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in . If you are accessing our Website from outside , please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than 5 years .
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
6. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
7. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Website , you have the right to request removal of unwanted data that you publicly post on the Website . To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website , but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
9. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at info@crimson-capital.com or by post to: