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NextSeed Privacy Policy

Effective May 2016

NextSeed US LLC (NextSeed) or its affiliates operate a public website at www.nextseed.co, and also offer an online intermediary platform for crowdfunded securities in accordance with Regulation Crowdfunding.  You may browse the public content on the website without establishing a user account, but you must establish a user account to view and use non-public content on the site and to use the platform.

This Privacy Policy covers NextSeed’s privacy policies for both its public site visitors and its platform users, and describes:

  • Data Collected: the personal data that NextSeed collects from you;
  • Use of Data: the ways that NextSeed 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 NextSeed might share your personal data with others.

The NextSeed 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 NextSeed’s retention of data. Platform users should review this Privacy Policy together with the Terms of Service.   

The statements below summarize our data practices. We used the Iubenda service at www.iubenda.com to generate a more detailed description of our data practices including third party elements and information providers. The Iubenda description appears as an appendix to this Privacy Policy. References in the Iubenda policy to the “Application” means our site and services.

If you have questions or there is anything that you do not understand about this Privacy Policy or NextSeed’s collection and use of your personal data, please do not hesitate to contact us at:[email protected]

Data Collected

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 NextSeed 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.

Use of Data

Generally NextSeed uses the personal and other data it collects to provide its platform services, to operate its website 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 or platform.  NextSeed may use the information to send you email or other communications about NextSeed’s or third parties’ content, product or services. If you provide NextSeed with information about your contacts, NextSeed 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 NextSeed 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

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 your activity.

Other

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

Children’s Online Privacy Protection: We will not knowingly collect any data from or about any person under the age of 13.


Exhibit A

Facts: What does NextSeed do with your personal information?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

  • Name and your business name
  • Contact information, including mailing and business address, phone and email details
  • Bank account information
  • Date of birth
  • Income, assets, debt, and other personal and business data
  • Correspondence with us by email and post
  • Social Security number and income
  • Account balances and payment history
  • Credit history and credit scores

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons NextSeed chooses to share; and whether you can limit this sharing. When you are no longer our customer, we continue to share your information as described in this notice.

 

Reasons we can share your personal information

Does NextSeed share?

Can you limit this sharing?

For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes – to offer our products and services to you

Yes

Yes

For joint marketing with other financial companies

Yes

Yes

For our affiliates’ everyday business purposes – information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes – information about your creditworthiness

Yes

Yes

For our affiliates to market to you

Yes

Yes

For non-affiliates to market to you

Yes

Yes

 

Please note:

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice.

However, you can contact us at any time to limit our sharing.

Questions

Email [email protected] or go to www.nextseed.co

Who we are

Who is providing this notice?

NextSeed is a limited liability company formed in Delaware and has its principal place of business at 4101 Greenbriar Dr, Suite 122K, Houston, Texas 77098.

What we do

How does NextSeed protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does NextSeed collect my personal information?

We collect your personal information, for example, when you:

  • Open an account or deposit money
  • Apply for a loan
  • Provide account information or give us your contact information
  • Show your driver’s license

We may also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only:

  • Sharing for affiliates’ everyday business purposes-information about your creditworthiness
  • Affiliates from using your information to market to you
  • Sharing for non-affiliates companies to market to you

State laws and individual companies may give you additional rights to limit sharing.

What happens when I limit sharing for an account I hold jointly with someone else?

Your choices will apply to everyone on your account – unless you tell us otherwise.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

  • Our affiliates include The Next Seed Inc. and NextSeed TX LLC.

Non-affiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

  • Non-affiliates we share with can include other financial services companies, lenders, insurance companies, retailers, membership clubs, or other consumerservice providers.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

  • Our joint marketing partners include other financial services companies,lenders, insurance companies or other consumer service providers.

Privacy Policy