Privacy Policy

The following describes the privacy policy of Fundivations, Inc.(“Fundivations”) (as amended or otherwise modified and in effect from time to time, the “Privacy Policy”) applicable to the services available through the Fundivations website, our mobile applications and/or other interfaces (collectively, the “Site”). By visiting the Site, you are consenting to the collection, use, disclosure, and processing of your personal data as described in this Privacy Policy. You may browse the public content on the Site without establishing a user account, but you must establish a user account to view and use non-public content on the Site and to access the funding platform.

This Privacy Policy covers Fundivations’ privacy policies for both its public Site visitors and its platform users, and describes:

• Data Collected: the personal data that Fundivations collects from you;
• Use of Data: the ways that Fundivations uses that personal data, including the ways that it may combine data it collects from you with data it acquires about you from other sources; and
• Disclosure of Data to Others: the circumstances under which Fundivations might share your personal data with others.

The Fundivations Terms of Service include terms governing data published by platform users, such as rights in published data, rights of other platform users to use published data, and Fundivations’ retention of data. Platform users should review this Privacy Policy together with the Terms of Service.

PRIVACY POLICY

Fundivations created this privacy statement to demonstrate our commitment to privacy. Fundivations will not knowingly sell, share, or rent this information to others in ways different from what is disclosed in this statement unless we are required to do so by law or have the good-faith belief that such action is necessary to conform to the edicts of the law, cooperate with law enforcement agencies, or comply with legal process served on our website. The following discloses our information gathering and dissemination practices for the Site www.title3funds.com. Fundivations collects information from our users at several different points on our Site.

Personally Identifiable Information

Fundivations typically receives specific data about its Site visitors only when such information is provided voluntarily, such as when our visitors request information, purchase or enroll for services, leaves a blog entry, provide resume information for employment opportunities, log into our portal system as Issuer, Subscriber or Partner, or send us e-mail. Of course, some of these activities require that you give us information, such as when you make a purchase, use a credit card to pay for products or services, submit your resume, or request certain types of information. When you provide personally identifiable information to Fundivations through our Site, it will be used to fulfill your request. The customer’s contact information is used to get in touch with him or her when necessary. Fundivations may also use such information to contact customers with updated information. Users may opt-out of receiving future mailings; see the choice/opt-out section below. Our Site may use cookies to keep track of the visit and in order to make it possible for the visitor not to enter information multiple times. We do not use persistent cookies that remain on the user’s hard drive after their browser is closed.

Public Site Visitors:

Our Web server captures your IP address, the time and duration of your visit, and the pages on the Site that your visit. It may also collect information about your browser, device, location and other information of the type collected by Web servers generally. We may use “cookies,” “web beacons” or other techniques to identify you or your device to your activity on the Site. Please see the section below captioned “Online Data Collection Technologies” for more information regarding our use of these techniques and your ability to restrict our collection of data in this manner.

We use third party Web analytics tools to capture information about your use of the Site, such as mouse clicks and scrolling activity. For example, we may use Google Analytics, Google Website Optimizer, or FullStory. The providers of these tools may capture data about your activity on our Site, via cookies and other techniques.

If you arrive at our Site by clicking on an advertisement or content published by a third party, that third party may provide information to us about your activity on their site. For example, we may use Google AdWords or other third party advertisers, or may sponsor links on other third party sites.

We may ask you to volunteer information about yourself using the Site, including personal data (such as your name and email address), demographic data (such as your profession, age and gender), and information about your general interests. We may also ask you to submit a photograph of yourself. Your submission of this type of information as a public Site visitor is not required.

We may permit third parties to display content on our Site. If you view this content, the third party may collect information about you. For example, we may permit content to be displayed by Google Fonts, Google Maps, You Tube or Vimeo. You should see the third party’s site for more information about the data they collect and their use and disclosure of the data.

Services Users:

You must provide personal data to establish a services account, such as name, physical address, phone number, email address, and other contact information.

As part of setting up your account, you are required to create a password, password hints, and provide answers to security questions. You are also required to provide financial information for the purpose of paying our fees, such as your credit number and expiration date.

You may be required or permitted to publish personal and financial data about yourself as part of the content you post to the public and non-public parts of the site, including the comment sections of the offering pages, by means of the platform, or to qualify you as an appropriate issuer or investor under applicable laws and regulations. You may also be required or permitted to publish demographic data or information about your interests and background. You may be permitted to publish a photograph of yourself. The nature of these publication features necessarily identifies you to your published content.

You may be permitted to share with Fundivations the personal data of your contacts via your local address book or via a third party service such as Facebook or LinkedIn.

If you contact us for support (whether by phone, chat, email or other means) we may record and save the contents of the communication.

If you purchase certain services for others, we will collect the names of the others as provided by you. You are fully responsible for ensuring that you have the right to provide such information, and Fundivations will not be under any obligations to make any inquiries or otherwise take action to confirm your right to do so. By providing any personal data of another customer, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such personal data as set forth in this Privacy Policy.

Use of Data

Generally Fundivations uses the personal and other data it collects to provide its platform services, to operate its Site and platform efficiently, and to provide a good quality experience for Site visitors and platform users. It may also use the information to show you advertisements and other content that may be of particular interest to you while you are on the Site. Fundivations may use the information to send you email or other communications about Fundivations’ or third parties’ content, product or services. If you provide Fundivations with information about your contacts, Fundivations will use that information to invite them to view your content, or for other purposes disclosed on the Site from time to time.

The providers of our analytics tools may use information they collect about your Site visit to show you advertisements or other content that may be of particular interest to you.

If you establish a platform account, we may tie the information we collect as part of your pre-login Site visit to your post login activity on the Site and platform.

If Fundivations acquires information about you from third parties, such as marketing or advertising firms, security services, or content providers, it may tie this third party provided information to the information it collects from or about you as part of your visit to the Site or use of the platform.

Here are some specific examples of the ways we use data we have about you:

• Account Transactions: We use your account data to communicate with you about account transactions or respond to your requests for support (such as fee payments, support requests, platform interactions with your issuers or crowd funders).
• Fraud, Abuse, Security: We use account and other data to screen for and reduce fraud, spam, abuse, and security problems. We may remove content or block access to the Site or platform in our discretion to reduce the risk of fraud, abuse and security problems.
• Business Improvements: We use the data we collect to improve our Site and platform, such as changes to the content or organization of the content, developing new platform features, identification of target audiences for our external advertising and publicity efforts.
• Legal Compliance: We use the data we collect to confirm that you are eligible under law to use the platform and to manage our compliance with the laws and regulations governing our platform.
• Newsletters and Other Promotional Content. We may use your data to send you communications of interest to you, including promotional communications. We may use Web beacons to track whether you actually view our messages or content.

Disclosure of Data to Others/Sharing

We use outside companies to host our Site and portal. We also use credit card processing and other companies to verify purchases and to bill users for goods and services. We select companies that indicate to us that they do not retain, share, store or use personally identifiable information for any secondary purposes.

We will not disclose your personal data to third parties except as follows:

• When we believe release is appropriate to comply with the law, to enforce our terms of use and other rights, or to protect the rights and safety of others. This may include exchanging information with government regulatory or law enforcement agencies, or with other companies and organizations for fraud protection and legal compliance.
• To persons who help us provide our products and services to you. We may provide personal and other information to third parties who work for us, such as companies that manage and monitor investment accounts, verify credit card information, process credit card payments, manage e-signing, analyze data, manage contact information and communications, remove repetitive information from customer lists, and provide marketing services. These providers are not authorized to further disclose your data or to use your data for any other purpose other than providing services to us.
• Our Site and platform are hosted by third parties and we use third party infrastructure monitoring services. These third parties may have inadvertent or incidental access to your data. These providers are not authorized to further disclose your data or to use your data for any purpose other than providing services to us.
• As part of a sale of our assets or a merger of our company. We may in the future sell all or part of our assets or be involved in a merger. It is customary for personal information to be included with the transferred assets in these types of transactions.

We may disclose data we collect from and about you in aggregate anonymous form for the purpose of improving our Site and services generally.

Online Data Collection Technologies

A cookie is a small text file that is placed on your device, typically a string of numbers and letters. The cookie is used to uniquely identify your device. Whoever places the cookie will typically use the information to associate each of your Site or services visits to your device, and to you personally if the cookie placer has information that identifies you personally to your device. Most browsers include features that enable you to block or restrict cookie placement. If you disable or restrict cookies, you may not be able to use all of the features of the Site or service that placed the cookie.

A Web beacon is a small electronic image that is served by a Web server when you view the Web page or email in which it is embedded. Generally, when you view the content in which the Web beacon is embedded, a call is placed to the Web beacon server that identifies your IP address or device information in a way that enables the operator of the beacon to identify your device, or you, to you activity.

Other

Security: We will use reasonable security measures to protect your personal data from unauthorized use and disclosure.

Children’s Privacy Policy

The Site is not intended for use by children, especially those under eighteen (18) years of age. No one under eighteen (18) years of age is allowed to use the Site, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children under the age of eighteen (18) years. If you believe that a minor has disclosed Personally Identifiable Information to Fundivations, please report this to us immediately by sending us an email at support@title3funds.com.

Links

This Site contains links to other sites. Please be aware that Fundivations is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every site that collects personally identifiable information. This privacy statement applies solely to information collected by this Site.

Surveys

From time-to-time we request information from users via surveys. We may use personally identifiable information to invite users to participate in surveys. Participation in these surveys is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age level). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site. Information collected may be used to contact the visitor at a later time. Users may elect to opt-out of future communications via the method below.

Choice/Opt-Out/Corrections

We may at times send you e-mail communications with information, marketing or promotional materials. If you prefer not to receive such e-mails from us, you may unsubscribe completely by contacting us through the contact form at http://www.title3funds.com/contact-us/.

Please note that opt-out requests may take up to five (5) business days to process. Please also note that at times we may need to send you e-mail communications that are transactional in nature such as service or termination announcements or payment confirmations, which are communications you will not be able to opt-out of.

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 e-mail 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 send us an email at support@title3funds.com. We may require up to five (5) 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 Fundivations’ cookies, Google’s 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 its functionality. You may also clear cookies from your computer under your web browser settings.

If you would like us to remove your Personally Identifiable Information from our database, please send us an email at support@title3funds.com.

We are not responsible for removing your Personally Identifiable Information from the lists of any Third Party Services or other third party who has previously been provided your information in accordance with this Privacy Policy.

Changes in Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to our Site. You should review this Privacy Policy 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 Policy 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 Policy.

This Privacy Policy 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 choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard either in the shall be brought and heard either in the California state courts located in Orange County, California, or the federal district court of California located in Orange County, California. You consent to the in personam 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.

Contact Information

Important Disclosure: Under the regulation, Fundivations, Inc.acts as an Intermediary platform for Issuers (companies selling securities in compliance with the regulations) and Subscribers (individuals purchasing securities offered by Issuers). Fundivations, Inc.does not provide any investment advice or make any investment recommendations to any persons, ever, and at no time does Fundivations, Inc.come into possession of Subscriber funds, which are transferred directly to a bank escrow account.

Attn: General Counsel Title3Funds, c/o Fundivations Corporation 301 Forest Avenue, Laguna Beach CA 92651