Effective Date: December 14th, 2022
At Caplight Technologies Inc. (the “Company”), your privacy is very important to us. We also value transparency and want to be clear about how we collect, use and share information about you.
This policy is here to help you understand:
WHAT INFORMATION WE COLLECT ABOUT YOU
We collect the categories of personal information listed below:
Information you provide to us
We collect information from you when you input it or otherwise provide it directly to us.
Account Information: We collect information about you when you create an account or sign up for Services. For example, you provide your name, email address, password, and phone number when you create an account. You also select whether you are a signing up as an investor or a shareholder. Depending on the Services you select, you provide your address, date of birth, and taxpayer ID, such as a social security number or other government issued ID number. We collect this information to verify your identity and to help the government fight the funding of terrorism and money-laundering activities, as required by US law. If you register or use the Services through third-party sites or applications, such as Google, we may gather information from them.
Bank, Brokerage and Other Payment Information: To transact with us, you may invest in a Caplight special purpose entity. You provide your banking information, including bank account and routing number and any other payment information, to the manager designated for that entity. You may provide the manager your brokerage information to enable the manager of the special purpose entity send you shares following the exit event.
Buyer Information: To make investments with Caplight’s special purpose entities, when you sign up for Services, you provide us information concerning whether you are investing on your own behalf or that of an institution, your status as an accredited investor, your investment objectives, risk tolerance, investment time-horizon, investment experience, and information concerning your income and/or net worth. You also provide certain commercial information and information about your investment preferences, which become a part of your investor profile, and may include how much you anticipate investing in certain asset classes, your target investment size per investment, the asset classes you have invested in, and sectors of interest.
For investments related to some issuers, you may also provide us employment information or representations that you are not affiliated with, or employed by, a competitor of that issuer. If you express interest in investing in a particular investment opportunity, you provide us information about your interest and preferences which may include the investment amount and other information regarding your interest in making an investment.
Seller Information: To sell private company equity through a Caplight special purpose entity, you provide us information and documents concerning your ownership of shares or options. For example, you provide information about the company in which you own the shares, ownership type, and the number of shares you want to sell. If you are a seller, you also provide us information and documents reflecting your vesting and other attributes applicable to your shares or options. You may also be asked to provide your spouse’s name and email address if you are married. You also provide information about your preferences, such as, for example, the price at which you desire to sell your shares.
Support Information and Other Communications: The Services include customer support, where you may choose to submit information or questions concerning a problem you are experiencing with a Service or questions you have about a Service. You may also provide, or be asked to provide, screenshots, documentation or information to help us address your problem or respond to your question.
You may also provide us with feedback and survey responses when using the Service, as well as other information you voluntarily provide to us when communicating with us, such as via email, or via other actions you perform when using the Services.
Trust Information: If you purchase or sell securities held in the name of the trust, you provide us with additional information and documents concerning the identity and contact information of individuals related to the trust.
Verification Information and Documents: If required to help us verify your identity, you may provide us a copy of your driver’s license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering, US Treasury department rules or regulations or other legal requirements. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship status.
Transaction Information: We collect information in connection with the transactions you become a party to through our Services as either a seller or a buyer (“Transaction Data”). Transaction Data includes, without limitation, the terms on which you purchase or sell securities and information relating to price, size, volume, class of securities, bids, offers, transfer restrictions, and any derivative data related thereto.
Information we collect when you use the Services
We collect the following categories of information about you when you use our services, including when visiting the Site and taking certain actions within the Services.
Information About Your Use of the Services: We collect certain information about you when you visit the Site and interact with any of our Services. We use third party software to monitor and record user interactions with our website. These track mouse movements, clicks, form inputs and general site navigation.
Device and Connection Information: We collect information about your computer, phone, tablet or other device you use to access the Services. This device information may include your operating system, browser type, IP address, URLs of referring pages, location, and device identifiers.
Cookies, Web Beacons, Pixel Tags and Other Similar Technologies: Caplight and its third-party service providers, such as our analytics and advertising partners, collect certain information using cookies, web beacons, pixel tags and other similar technologies to provide functionality, enable and support security features, recognize you across different devices, improve our offerings, understand how you use and interact with our Services, improve performance of Services, and otherwise manage and enhance Services. “Cookies” are simple text files stored on your device for use by a browser. “Web Beacons” or “pixel tags” are small images, often transparent, on a website or email that are used to observe if you have accessed content. Using cookies, web beacons or pixel tags, or other tracking technologies are standard practices on internet web sites.
Some web browsers transmit “do-not-track” signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers.
We use session cookies to make it easier for you to use our Services and to identify you while you are on the Site or Application. We also use persistent cookies to make it easier for you to navigate the Site and track whether you are logged into the Site. A persistent cookie remains on your device’s hard drive for an extended time. You can remove persistent cookies by following the directions provided in your internet browser’s “help” file. If you reject persistent cookies, you will still be able to view the Site, but your ability to use some areas of the Site, such as automatically-generated recommendations, will be limited.
Information we receive from other sources
We receive information about you from third-party services and business partners.
Third-Party Identity Verification Service Provider: We receive information about you from a third-party identity verification service provider to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services.
Marketing and Advertising Services and Partners: We receive information about you and your activities on and off the Services from third-party service providers, such as Google, RocketReach, Apollo, Datadog, Logrocket, Heap, LinkedIn and other advertising, social media and market research partners who provide us with information about you, and/or your engagement with and interest in our Services.
Business Partners: We may receive information about you from our third-party partners, under referral programs, partnership agreements and/or under joint marketing arrangements.
HOW WE USE INFORMATION WE COLLECT
We use the information we collect based on the Services you choose to receive. The specific purposes are described below.
To Provide the Services and Personalize Your Experience: We use information about you to provide the Services to you, including to process transactions for you, authenticate you when you log in, verify your identity, and, if you are seeking to invest, determine your eligibility for investments. We also use information you provide to validate that information, comply with legal requirements, provide customer support and communicate with you, and operate and maintain the Services.
We also use information about you to personalize and improve your experience while using the Services and to determine effectiveness of the Services. We also use information about you and your activities to provide an integrated experience, such as allowing you to access the Services from multiple devices.
To Communicate With You About the Services: We use your contact information to send communications to you (typically via email) about your transactions, including confirming the terms on which you purchase or sell securities, updating you on the status of transactions and related deadlines, responding to your questions or comments, and providing information received from the issuer or, when applicable, other parties to your transactions. If you are eligible to invest through the Site, we send you notifications about potential investment opportunities available through the Site. We also provide tailored communications to you based on actions you take on the Site.
To Operate the Services: We share information about you as needed with our own service providers, including financial institutions, fund administrators, accountants, auditors, lawyers, payment providers, information technology staff, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Site and the Services.
For Research and Development: We strive to make our Services better, smarter, faster, more secure and easier to use. We collect information about how people use the Services and feedback provided directly to us to identify trends and problems, usage and activity patterns, and areas for integrating and improving our Services. We may also test and analyze certain new features with some users before rolling out the features to all users.
To Market, Promote and Drive Engagement With the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of interest to you, including by email and by displaying our content on other websites and applications, such as on platforms including Google or Facebook. These communications are intended to increase engagement and what you get out of the Services, including information about new features, new content, and events we think may be of interest to you. We also communicate with you about new products and services and promotions.
We do not – and do not plan to – rent or sell personally identifiable information about you to other people or to non-affiliated companies.
For Safety and Security: We use information about you and your Service use to verify your identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies. We also use your information to debug, identify and fix errors that impair how our Services function.
As Required by Law or Regulations: We retain information about you that is required by US law or regulation, including those applicable to the sale of securities or operating an investment advisor or broker-dealer. In general, we are required to retain these records for at least three years, and up to six years (and in some circumstances, longer). We may keep some information longer to meet our needs and those of our customers, even after you close or deactivate your account, including for backup, archives, contract enforcement, dispute resolution. We may access and disclose information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.
For a Merger, Sale or Other Asset Transfer: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of Caplight’s assets, or other corporate transaction affecting Caplight, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract.
Legal Bases for Processing (for EEA users): If you are an individual residing in the European Economic Area (“EEA”), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the General Data Protection Regulation (“GDPR”). The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services.
To do so, please email us at firstname.lastname@example.org
HOW WE SHARE INFORMATION WE COLLECT
We manage a private company equity and equity derivatives marketplace, and we want it to work well for you. This means sharing information through the Services and with certain third parties. We share information we collect about you with third parties in the ways discussed below, including in connection with possible business transfers.
With Affiliates of Caplight: If you are a party to a prospective or actual transaction, we share information about you with our affiliates, including our broker-dealer, Caplight Markets LLC, to provide you Services relating to that transaction.
We also provide your information where necessary for a transaction or to comply with legal requirements. For example, we may provide certain aspects of your information to financial institutions, payment processors, fund administrators, accountants, auditors, lawyers, payment providers, third-party hosting service, email and technology service providers, information technology staff, advisors, affiliates, marketing and analytics partners, or third-party verification services.
We do not and will not sell your personally identifiable information. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your personal data.
We may share aggregated, deidentified and/or anonymized information that does not specifically identify you or any individual user of our Services for any purpose with any third-parties, including but not limited with advertisers, national industry organizations, and prospective affiliates, or as permitted or required by law, or to protect our rights.
With Regulators: We may share information about you with US, state or international regulators where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders or subpoenas.
We may also share information about you to protect the security and integrity of our Services, to protect Caplight’s interests, or those of other persons or the public.
With Business Partners: We may share information about you with our third-party partners under referral programs, partnership agreements or under joint marketing arrangements.
With Your Consent: We share information about you where you have given us consent to do so for a specific purpose. For example, we may disclose information to your financial advisor, accountant attorney or spouse, or other individual or company you authorize to receive information about you.
HOW WE STORE AND SECURE INFORMATION WE COLLECT
We take steps to ensure that your information is treated securely and in accordance with this policy. While we use industry-accepted security principles, practices, and tools, the internet is not 100% secure and we cannot ensure or guarantee the security of data, during transmission through the Internet or while stored on our systems or otherwise in our care. We do not accept liability for unintentional disclosure.
By using the Service or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing.
We use a data hosting service provider in the United States to host the information we collect, and we use technical measures to secure your data. We use industry-accepted practices, including 256-bit encryption, to protect customer-related information. Information is encrypted at rest and in transit from client to web to web server, and to the database.
We request third party service providers to agree to keep your information confidential by entering into agreements that limit their use of the information they receive about you for purposes of performing the services for which they are being retained.
OTHER IMPORTANT PRIVACY INFORMATION
You have choices and rights available to you when it comes to your information. They are summarized below.
Your Rights as a California Resident: Residents of California have the right to request from us, one time per year, certain information with respect to the types of personal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year.
To exercise your rights, please use one of the submission methods mentioned below under “Submitting Requests Pertaining to Your Information".
Your Rights as a Vermont Resident: We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, please contact us for assistance at email@example.com though we will no longer be able to provide you Services or access to the Site.
If You are a European Economic Area Resident: If you are an EEA data subject, you may review, correct or update the personal data you provide at any time.
If you would like to exercise your GDPR rights, please use one of the submission methods mentioned below under “Submitting Requests Pertaining to Your Information”.
In the event of a data breach, we will endeavor to notify you within 72 hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the General Data Protection Regulation. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.
Access to Your Data and Documents: You may review, correct or update the personal data you provide at any time. You may access your documents relating to your transactions at any time by logging in into your account and navigating to the “My Documents” and the “My Transactions” section of the Site or Application. If you need assistance, please contact us at firstname.lastname@example.org.
Unsubscribe Options: If you chose to use the Services, you will receive periodic emails or other electronic communications from us which, based on the information you provide, may be of interest. If you no longer wish to receive our communications, you may unsubscribe by following the instructions included in each communication.
Children’s Privacy: The Site and our Services are not directed to any person under the age of 18. If you become aware that your child has provided us with personal data without your consent, please contact us at email@example.com. We do not knowingly collect or solicit information from, market to, or accept services from children.
Lost or Stolen Information: You must promptly notify us if you become aware that any information provided by or submitted to the Site is lost, stolen or used without permission.
Changes to this Policy: Each time you visit the Site or use the Services, the current version of the Policy will apply. When you use the Site, you should check the date of this Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. We may require you to affirmatively assent to a revised version of this Policy as a condition of continuing to use the Site or our Services.
Submitting Requests Pertaining to Your Information: If you would like to make a request regarding your information, you may do so, free of charge, by clicking firstname.lastname@example.org You will be redirected to fill out a form with certain information about your request. *If you have a registered account on the Site or the Application, please make sure to login to your account before submitting your request.* This will help us verify your identity.
Please note that for all requests, we will need to verify your identity to confirm that you are the individual about whom we have collected personal information.
Contact Us: Your information is controlled by Caplight Technologies Inc. If you have any questions or concerns about how your information is handled you may contact us at:
Caplight Technologies Inc.
1160 Battery Street East
San Francisco, CA 94111
Leave your email here and feel free to contact us with your questions.
Investment opportunities posted on this website are "private placements" of securities that are not publicly traded, are subject to holding period requirements, and are intended for investors who do not need a liquid investment. Investing in private companies may be considered highly speculative and involves a high degree of risk, including the risk of substantial loss of investment. Investors must be able to afford the loss of their entire investment.
Caplight Markets LLC (“Caplight Markets”) is a subsidiary of Caplight Technologies Inc. Caplight Markets is a broker/dealer registered with the Securities Exchange Commission and is a FINRA/SIPC member firm.
Equity securities and equity derivatives are offered through Caplight Markets. Check the background of this firm on FINRA’s BrokerCheck.
Caplight and logo are trademarks of Caplight Technologies Inc. Other trademarks are property of their respective owners.