Last Updated: March 31, 2019
How does the Platform Work?
You can make general use of the Platform without providing any PII to iintoo. However, you may need to provide us or third parties with certain of your PII in order to use certain of the Platform’s functionality, such as engaging in investment transactions through the Platform (“Transactions”) or posting comments and building a network of other User contacts.
What type of PII does iintoo collect from you and how do we use it?
You need to provide us with certain PII in order to engage in Transactions, including without limitation your name and email address, and payment information. You will also need to provide us with certain PII in order to use other aspects of the Platform, such as our social networking functionality. Thus, we collect information related to Transactions in which you invest or otherwise indicate an interest and when you use our social networking functionality, including without limitation your PII which is used or referenced when you message, interact or otherwise communicate with other Users through the Platform. We also collect non-PII information about how you use the Platform, such as the types of content you view or interact with or the frequency and duration of your activities, and this information can be associated with your PII. iintoo may provide your PII to individuals or entities who work on our behalf or with us. These individuals or entities may use your PII to help fulfill your requests and to help us communicate with you about different investments offered through the Platform. For example, we will share your PII with our third parties who need to pre-approve investors to make sure they are qualified to engage in Transactions. We also may transfer or permit the transfer of certain of your PII or other information to other service providers and other third parties who assist us in operating the Platform.
iintoo may also use and disclose PII to improve and enhance your experience on the Platform and for other purposes. For example, from time to time, we may use and share PII with third parties to show general demographic and preference information among Platform users. In these circumstances, however, the shared information will neither contain nor be linked to any of your PII.
Please note that if we receive your Opt-Out Request after having shared your PII with a third party for direct marketing and/or other purposes or having otherwise transferred or disposed of your PII, we may not have the ability to control the use of such PII by any third party, and in such an event we shall not be liable or otherwise responsible, directly or indirectly, for any damages or loss caused or alleged to be caused by or in connection with the use of such PII by any such third party or resulting from any such transfer or disposition.
Which of your PII may be viewable to other Users?
The Platform has been designed so that many aspects of your Transaction history (including which prospective Transactions have been viewed by you) is publicly viewable unless you take affirmative steps to change your privacy settings to keep such information limited so that it is viewable only to your approved contacts only or even so that it is not viewable to any third party. The responsibility to change the privacy settings of your profile from the default setting of being publicly viewable (upon your registration with us) is exclusively yours, and if and until you change the settings of your profile all of your transaction history will be publicly viewable to all Users. So if you do not want other Users viewing your activity history, you must change your privacy settings before you navigate the Platform.
Under what other circumstances may we release PII?
What other information does iintoo collect?
Do I have the ability not to be identified by iintoo?
How do we store information?
iintoo takes steps consistent with commercially reasonable industry standards to secure PII collected from you from loss, misuse, unauthorized access and destruction while under our control. However, please note that despite our efforts to protect information provided to us, we cannot guarantee that such information (including your PII) will not be lost, disclosed or accessed by accidental circumstances or by the unauthorized acts of others.
Does iintoo provide links to other websites?
What are our policies regarding children?
The Platform is intended for general use by persons who have reached the age of consent in their state of residence and it is not targeted to anyone under thirteen (13) years of age. iintoo does not knowingly collect PII from anyone under thirteen (13) years of age. If we learn that we have unwittingly collected PII from anyone under thirteen (13) years of age, we will promptly delete such information.
Do we have a mechanism to address the removal of PII and complaints about the handling of information that we collect?
If you wish to remove PII that you have submitted to iintoo, please send us an email requesting such removal to email@example.com. If you have questions or concerns about any of our information collection or handling practices, please contact us at firstname.lastname@example.org or write to us at iintoo Investments Ltd., 800 Third Avenue, 37th Floor, New York, NY 10022