Date: February 9, 2021
Purchase Capital LLC (“Purchase Capital” “we,” “our,” or “us”) is committed to safeguarding and handling your Personal Information in a responsible and secure manner.
We may modify this Policy at any time, without prior notice, and changes may apply to any Personal Information we already hold about you, as well as any new Personal Information collected after the Policy is modified. If we make changes, we will notify you by revising the date at the top of this Policy. We will provide you with advanced notice if we make any material changes to how we collect, use or disclose your Personal Information or that impact your rights under this Policy. If you continue to access or use our Services after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.
In addition, we may provide you with real time disclosures or additional information about the Personal Information handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your Personal Information.
Section 1 – Information We Collect Through Your Use of the Services
Personal Information is any information that identifies you or makes you identifiable. We collect different types of Personal Information when you’re accessing or using our Services, including:
- Information you provide to us. In connection with the Services, we may ask you to provide these categories of Personal Information:
- Business and Professional Information: Examples of business information collected by us include your name, employer/company, job title, telephone number, business and/or personal address(es), email address, information regarding your job, identification numbers (such as a passport number or other government issued ID), and/or other information regarding your preferences where it is relevant to the Services.
- Financial Information: Examples of financial information include bank account details, credit card number, money transfers (including communications regarding bank transfers), assets, investment profile, credit history, debts and expenses. A third-party service provider stores and processes this information securely on our behalf.
- Voluntary Information: Information you provide to us voluntarily by completing web forms, participating in polls, submitting information to us or contributing to blogs, forums, postings, contacting customer service, and other mediums constitutes Voluntary Information.
- Usage Information automatically collected. When you use the Services online or through our website, we automatically collect information about the Services you use and how you use them (“Usage Information”), as described below.
- Service Data: We collect information about your interactions with the Services, such as the pages or other content you view, and other actions you perform while using the Services.
- Log Data: We automatically collect log information when you use the Services. This might include your IP address, access times, hardware and software information, device information, device event information (e.g. crashes, unsuccessful logins, browser type), the web page you’ve viewed or engaged with before or after using the Services, and other relevant information.
- Cookies and Similar Tracking Technologies: We may use various tracking technologies to collect and store information about your use of our Services. We use these tools to ensure that you receive a personalized experience, to provide you with certain functions on our Services, to keep your account safe, and to improve and optimize our Services. See Section 9 below for more information.
Section 2 – How We Use Your Information
Your Personal Information can be used for various purposes, including:
- To Provide Our Services. When you access or use our Services, we process certain Personal Information about you to administer and maintain our business. Some examples of how we process your Personal Information in our Services include, but are not limited to:
- making, maintaining, managing and disposing of our investments;
- conducting due diligence and evaluating business opportunities;
- developing new investment opportunities; and
- managing, operating and growing our business, administering the Services and managing investor accounts, including through the use of third party service providers.
- To Communicate with You. When you communicate with us or submit information to us, you will receive Service-related communications. Our Service-related communications are transactional messages about your business, investment opportunity, policy changes, or other Service-related notifications. However, service-related communications are necessary for us to continue to provide our Services to you.
- Marketing Communications. We may also use your Personal Information for marketing, promotional, or business development related communications and initiatives. You can manage your email preferences and opt out of certain communications by emailing us at firstname.lastname@example.org.
- To Enforce our Terms, Agreements, or Policies. We use your Personal Information to make sure our terms, policies, and agreements with you and any third parties are enforced. We actively monitor, investigate, prevent, and mitigate any suspected or actual prohibited activities in our Services. We are required to process your Personal Information for this purpose to provide our Services.
- For Research and Analytics. We may process your Personal Information to improve, optimize, or expand our Services or features of our Services and to understand market trends and developments. We do so by processing information about your use of the Services, any information you provide to us. We take additional security measures when processing your Personal Information for such purposes, such as by de-identifying your Personal Information and limiting access to such data.
- To Comply with Applicable Laws. We may be required to process your Personal Information under certain laws and regulations, such as tax laws. We will also process any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that we may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the Purchase Capital User Agreement and other policies; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Purchase Capital, its employees, its users, its clients, and the public. We cannot provide the Services to you without such processing.
Section 3 – How We Share Your Information
We may share your Personal Information as follows:
- Third-Party Service Providers. We may use third parties to perform certain services on our behalf in connection with the Services such as:
- to process and store data, including your Personal Information;
- to track, analyze, and modify our Services;
- for marketing, advertising, and event planning; and
- to support our IT and security efforts.
Google Analytics. Google Analytics is one of our analytics service providers. Learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.
The third parties we work with do not have permission to use the information we share with them beyond what is necessary to assist us. We execute agreements with third parties to ensure they use adequate safeguards when processing your Personal Information in accordance with this Policy.
However, certain third-party service providers, such as payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Personal Information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
- To Perform Investment Services. We will also disclose Personal Data to the following categories of third parties: (i) anyone involved in the matter we are working on, including counsel, counterparties, experts, mediators, opponents, attorneys and witnesses, (ii) law enforcement, tax and regulatory agencies and bodies, and (iii) insurers.
- Between Purchase Capital affiliated companies. Since Purchase Capital is a global business operating in different countries, we may transfer Personal Information between Purchase Capital affiliates, offices, departments, and across national borders for the purposes of international administration and operations.
- Merger, Bankruptcy, or Corporate Reorganization. We may disclose and transfer your Personal Information to a subsequent owner, co-owner, or operator of Purchase Capital or the Services, or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets (i.e., a bankruptcy proceeding), or other corporate change. We will notify you with any choices you may have regarding your Personal Information when we are engaged in a merger, bankruptcy, or corporate reorganization.
- Legal Obligations and Safety. We may share your Personal Information if it is reasonably necessary to:
- Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);
- Comply with requests or investigations by public authorities;
- Comply with applicable laws or regulations;
- Enforce or apply the Purchase Capital policies or policies of our business partners;
- Protect the security or integrity of the Services; or
- Protect the rights, property, or safety of Purchase Capital, our employees or users, partners and affiliates, or other natural persons.
- For any other purpose, with your consent. We may share your Personal Information on your behalf or at your request. We will only do so with your specific consent. If you provide your consent to share your information, you may withdraw your consent at any time. Withdrawing your consent will not undo or reverse the lawfulness of any previous processing, and in some cases Personal Information may not be retrieved once shared. Contact us at email@example.com if you would like to withdraw your consent.
Section 4 – Your Choices
- Self-Reported and Voluntary Information. You may choose not to provide us with some of your Personal Information. For example, you are not required to complete any survey we send to you. Note, if you do not provide certain Personal Information, we may not be able to fully administer our services, make investments, or otherwise analyze a company.
- Communication Preferences. If you do not want to receive marketing emails from us, please adjust your communication preferences or click the unsubscribe link within the email you received from us. You will not be able to unsubscribe from Service-related communications as they are necessary for us to continue offering you the Services.
Section 5 – Third-Party Services
Section 6 – Security
To protect your Personal Information, we take reasonable precautions and follow industry standard practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. You should be aware that, unfortunately, no system can be 100% secure. There will always be a risk that your Personal Information gets compromised.
Section 7 – Children’s Privacy
By using this site, you represent that you are at least the age of majority in your jurisdiction of residence, or that you are the age of majority in your jurisdiction of residence and you have given us your consent to allow any of your minor dependents to use this site. This website is not intended for children under the age of 13. Please contact us if you believe we have collected Personal Information about a child without consent from their parent or guardian so we can take action to prevent such access and to delete their Personal Information from our Services.
Section 8 – Retention
We generally retain your Personal Information as long as necessary to fulfill the purposes of collection or to comply with applicable law. Otherwise we will try to delete your Personal Information upon your request or when we no longer need it for the purposes it was originally collected. We will not delete any Personal Information that also relates to other individuals, unless such other individuals also wish to delete their Personal Information at the same time.
Section 9 – Cookies and Other Tracking Technology
We use the following types of Cookies:
- Required Cookies. Required Cookies are required for providing you with features or services that you have requested. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services.
Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
Information about Interest-Based Advertisements
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Information) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit http://www.networkadvertising.org/choices/ or www.aboutads.info/choices/.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
Section 10 – Notice to Individuals in the State of California
Marketing. California law permits California residents to ask Purchase Capital for a notice that identifies the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us at the address provided under the “Contact Information” section.
Do Not Track Signals. Currently, we do not monitor or take any action with respect to Do Not Track signals or other mechanisms, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
Questions & Contact Information
If you would like to register a complaint, or simply want more information please contact us at firstname.lastname@example.org or by mail at:
Purchase Capital, LLC
1395 Brickell Avenue
Miami, FL 33131
Telephone: +1 (305) 697-9600