Last Updated: February 15, 2023
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 your 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 Your Privacy Rights?
In some regions (like the EEA, UK, and Canada), you may have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us [email protected] or write to us at iintoo Investments Ltd., 211 East 43rd Street, Suite 500, New York, NY 10017.
We will consider and act upon any request in accordance with applicable data protection laws. If you are located 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: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at [email protected] or write to us at iintoo Investments Ltd., 211 East 43rd Street, Suite 500, New York, NY 10017. However, please note that this will not affect the lawfulness of the processing before its withdrawal of your consent nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than your consent.
You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at [email protected] or write to us at iintoo Investments Ltd., 211 East 43rd Street, Suite 500, New York, NY 10017. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to respond to service requests, or for other purposes.
State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents’ privacy rights, visit https://oag.ca.gov/privacy/ccpa.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Platform that are California residents to request, once a year and free of charge, certain information regarding our disclosure of personal information to third parties for their direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. To make such a request, please send an email to [email protected] or write to us at iintoo Investments Ltd., 211 East 43rd Street, Suite 500, New York, NY 10017.
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
- Confirm whether we process their personal information.
- Access and delete certain personal information.
- Data portability.
- Opt-out of personal data processing for targeted advertising and sales.
To exercise any of these rights please contact us at [email protected] or write to us at iintoo Investments Ltd., 211 East 43rd Street, Suite 500, New York, NY 10017.
Other states may afford their residents similar or different rights with respect to their privacy and this policy does not constitute legal advice and should not be considered to be a comprehensive listing or description of such rights. You are encouraged to seek legal counsel to determine whether you have additional privacy or other rights under the laws of any state, country, or other jurisdiction.
Privacy Rights if You are Located in the EU or UK
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time;
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services,
- Support our marketing activities, and/or
- Diagnose problems and/or prevent fraudulent activities;
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. Applicable law may require us to keep such efforts confidential; and/or
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
Privacy Rights if You are Located in Canada
We may process your information if you have given us specific permission or express consent to use your personal information for a specific purpose, or in situations where your permission can be inferred or where there is implied consent for us to use your personal information for a specific purpose. You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
- For investigations and fraud detection and prevention;
- For business transactions provided certain conditions are met;
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
- For identifying injured, ill, or deceased persons and communicating with next of kin;
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
- If the collection is solely for journalistic, artistic, or literary purposes; and/or
If the information is publicly available and is specified by the regulations. What are our policies regarding children?
No one under age 16 may provide any information to us or on or through the Platform. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Platform or through any of its features, or provide any information about yourself to us, including, without limitation, your name, address, telephone number, email address. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected] or write to us at iintoo Investments Ltd., 211 East 43rd Street, Suite 500, New York, NY 10017. 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 protected]. If you have questions or concerns about any of our information collection or handling practices, please contact us at [email protected] or write to us at iintoo Investments Ltd., 211 East 43rd Street, Suite 500, New York, NY 10017.