Privacy Policy - Equity Street Capital

Your privacy is very important to us.

This following Privacy Policy describes how and why Equity Street Capital and our subsidiaries and affiliates (collectively, “the Company,” “us,” “we,” or “our”) collect, use, store, disclose, and share your personal information collected anytime you communicate with us, whether in person, by phone, or through the use of EquityStreetCapital.com and/or any other related website that links to this Privacy Policy (the “Website”).

By interacting with the Company in any way, including without limitation, through our team members, websites, mobile applications, products, and services, you consent to our use of your information that is collected or submitted as described in this Privacy Policy. We may change or add to this Privacy Policy, so we encourage you to review it periodically.

This Privacy Policy was last updated on 12/1/2023

What Type of Information Do We Collect?

We may collect the following categories of personal information, although, not all categories may be collected for every individual because it may depend on whether you are a visitor to our websites or you are a participant in one of our opportunities:

Personal identifiers, such as your name and mailing address
Device and online identifiers and related information, such as your telephone number and email address
Internet, application, and network activity, such as cookie IDs and browser visits
Government identifiers, such as national identification numbers and driver’s license numbers
Demographic information, such as age and date of birth
Financial information, such as bank accounts, retirement accounts, investments, etc.
Characteristics of protected classifications under state or federal law, such as gender and nationality
Investing history information
Location information, such as geo-location information
Employment information, such as occupation, title, licenses and professional memberships
Background and criminal information
Education information, such as degrees and schooling information
Individual preferences and characteristics
Behavioral information, such and when and how often you access your account, and how often you communicate with us.

How Do We Collect Information?

We may collect information about you in a few different ways:

We collect information directly from you when you share information with us; for example, when you register for an offering webinar, fill out a survey, complete paperwork or online forms, make an investment, create an account, post a review or comment on one of our social media pages, or request customer service or contact us with an inquiry or request;
We collect information indirectly and passively from you through technology, such as through a cookie placed on your computer when you visit our websites or from the device or browser you use to access our services (see more below).
We also collect information from third parties and other sources to help us correct or supplement our own records, improve the quality or personalization of our services and marketing, and to prevent or detect fraud. For example, we belong to ad networks that may use your browsing history across participating websites and mobile services to show you interest-based advertisements, and you may also see our ads for Equity Street Capital on participating websites and mobile services based on how you browse.

We reserve the right to combine personal information collected from any and all sources. Our goal is to only collect the information that is needed to support our business.

Device Information: In some scenarios we may collect technical information when you visit our websites or use our mobile applications or services. This may include information such as Internet Protocol (IP) address, the type of mobile device you use, your device operating system and browser type, a unique device identifier, the address of referring websites, the path you take through our websites, pages visited, average time spent on our websites, and other information about your session on our websites.

Browsing Information: In some scenarios we may use our own and third-party technologies such as cookies, web beacons, and mobile device identifiers to collect information about the use of our websites and mobile services. We use these tools to provide an integrated and more personalized customer experience for you. For example: a cookie, which is a small data file that can be placed on your hard drive when you visit certain websites, allows us to provide you relevant information as you use or return to our sites; web beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our websites and other sites were effective. We also use tracking pixels (i.e. Google Analytics) to aid in measuring and tracking where our website traffic is coming from and to track the performance of our site. Finally, we use remarking pixels from Facebook and Google to aid in customized, targeted follow up advertising.

Under certain circumstances, we may permit third parties to collect information on our websites for their own business purposes using cookies, web beacons, iframes and similar technologies. To learn more about cookies, including information on what cookies have been set on your computer and how cookies can be managed and deleted, visit https://www.ftc.gov/site-information/privacy-policy/internet-cookies.

Do Not Track Disclosure: We do not respond to “Do Not Track” signals.

How We May Use Personal Information

We may use your Personal Information to provide you with services or potential investing opportunities. We also use your Personal Information to support our business functions, such as fraud prevention, marketing (i.e., for affiliates to offer complimentary services), and legal functions.

Some examples include:

To fulfill your investment, requests for services or provide customer service
To create and maintain your account
To conduct auditing and monitoring of engagement
To conduct marketing, personalization, and third-party advertising through our family of companies and affiliates
To protect the security and integrity of our websites, mobile services and our business, and help prevent fraud
To update our operational and technical functionality
To conduct business analysis, such as analytics, projections, identifying areas for operational improvement
To conduct research and development
To fulfill our legal function or obligations

To do the above, we combine Personal Information and non-personal information, collected online and offline, including information from third party sources. We also may transfer or share your personal information for these purposes within our corporate family of companies and affiliates, as permitted by law.

How Do We Share Your Personal Information Outside of Equity Street Capital?

All of the categories of Personal Information that we collect have been shared for a business purpose with our family of companies and affiliates. We do not sell or rent your personal information for monetary consideration; however, we may receive an affiliate referral fee if you purchase a product or service from an affiliate company. We may share your Personal Information in other circumstances, such as in order to conduct our business, for other companies to offer you complimentary products and services, in the event all or a part of our business is merged, sold or reorganized, when legally required, as described below, or with your consent.

We will not share your personal information outside of our corporate family of companies and affiliates, except in the following circumstances:

Service Providers

We share personal information about you with service providers that help with our business activities, including shipping vendors, payment card processors, marketing and advertising vendors, and companies that help us improve our products and services. Your personal information may be stored and processed by our service providers in the United States or other locations where the service providers or Equity Street Capital maintain facilities.

Legal Requirements and Protection of Our Company and Others

We may share your Personal Information in other special circumstances, which include situations when sharing is required by law, or we believe sharing will help to protect the safety, property, or rights of Equity Street Capital, our investors, our team members, or other persons. Examples include:

Protecting our intellectual property
Identifying and addressing fraud or financial risk
Providing personal information to law enforcement at their written request
Responding to a subpoena or other valid legal inquiry
Responding to an investigative body in the case of a breach of an agreement or violation of law.

Business Transfers

In the event that all or a part of our business is merged, sold or reorganized (including transfers made as a part of insolvency or bankruptcy proceedings), personal information about you could be shared with the successor business. We will use reasonable measures and recommend that any successor treats your information in accordance with this Policy.

Advertising Related Activities

We may share aggregated or pseudonymous information (pseudonymous information includes things like: device identifier, type of device, IP addresses, cookies and other information associated with your browsing and app usage) with other companies, such as publishers, advertisers, measurement analytics providers, and others. We do not share information that directly identifies you (information such as name or email address) with these companies.

Advertisers and partners may also use their own cookies. We do not control use of these cookies and expressly disclaim responsibility for information collected through them.

With Your Consent

In circumstances other than those described above, we will ask for your affirmative consent before we share your personal information outside of our corporate family of companies and affiliates.

How Can You Make Choices About Receiving Marketing, Promotional, and Other Information?

Equity Street Capital may send you marketing, promotional or other information. In certain cases, when interacting with us, you may be provided with a choice to opt-in or opt-out of receiving such information. In other cases, you will not be presented with this choice. If you, at any time, choose to opt-out of receiving such information, we will abide by that marketing preference. Moreover, at any time (no matter what you have chosen or informed us of in the past), you may send us an email to support@equitystreetcapital.com to update your marketing preference or to request that we delete your personal information; we will abide by that preference and update your personal information accordingly. You may of course also follow the unsubscribe instructions contained in the marketing communications you receive from us.

Some of our mobile services use your device’s location information. You may be able to adjust the settings of your mobile device at any time to control whether your device communicates this location information. We may also offer additional controls on our use of your mobile location information.

Kindly note that no matter what your marketing preferences are, we may contact you to acknowledge, confirm or fulfill any order that you place, to respond to you, or for other legitimate business reasons.

Marketing Preferences

When we are sending marketing communications to you, we use the following standards:

We use an opt-in standard for automated phone and text messages. Opt-in means we will only conduct the activity with your affirmative consent.
We use an opt-out standard for email, app notifications, postal mail, and for sharing personal information with our affiliates and any companies outside our corporate family of companies for their use in direct marketing of their products and services. Opt-out means we or they may contact you, but will stop upon your request (as described below).

If you contact us by email or mail, please be sure to include your full name, the types of communications you would like to receive or not receive, and your related contact information. For instance, if you would like to opt-out of mail, include your mailing address. Please allow sufficient time for your marketing preferences to be processed. Please note that postal mailings are often prepared many weeks in advance, and you may continue to receive mail for six to ten weeks.

Since we do not accept opt-out requests from third parties, please communicate your request directly to us through one of the mechanisms mentioned in this Privacy Policy.

Please know that, even if you opted out of receiving marketing communications from us, we may still contact you for transactional or informational purposes. Some examples are contacts for customer service or reminder notices. We may also need to contact you with questions or information regarding your investment.

How Do You Access and Update Your Personal Information?

We provide you with various ways to access or update your personal information, including contact and account information. We also take reasonable steps to keep your personal information accurate and complete.

You can access or update your personal information, including contact or account information, in the following ways:

If you have created an account on our website, log into your account. Once you do, you will be able to enter and update your own contact information.
Contact us through one of the ways listed in Privacy Policy. Please include your current contact information, the information you are interested in accessing, and your requested changes. We will provide you the personal information requested if it is reasonably available, unless it infringes on the privacy of other individuals, and subject to reasonable limitations provided by law and internal procedures. Otherwise we will describe the types of information we typically collect. We will provide access and make the changes you request, or will provide an explanation of what actions we will be able to take with regard to the request.
If you need to access your personal information related to a specified service provided to you by an Equity Street Capital service provider or business partner or affiliate, we will refer you to the service provider or business partner or affiliate.

If you are a California resident, please refer to the “What Are Your California Privacy Rights?” section for additional information on your rights under the California Consumer Privacy Act.

How Do We Secure Your Personal Information?

We recognize the importance of maintaining the security of our customers’ personal information. We use reasonable security measures, including physical, administrative, and technical safeguards to protect your personal information.

We have team members who are responsible for helping to protect the security of your information. Whether you are on our website or our mobile services, we use reasonable security measures, including physical, administrative, and technical safeguards. These measures may include physical and technical security access controls or other safeguards, information security technologies and policies, procedures to help ensure the appropriate disposal of information, and training programs.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website or services, you are responsible for keeping this password confidential. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal Information transmitted to our websites.

How Does Equity Street Capital Protect the Privacy of Children Online?

The Website is not designed to solicit information from individuals under the age of 18. We do not knowingly collect or store any personal information from anyone under the age of 18. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or legal guardian and believe we may have inadvertently collected personal information from your child, please contact us at: support@equitystreetcapital.com.

Your California Privacy Rights

Shine the Light Disclosure
Under the California “Shine the Light” Act, if you reside in California and have an established business relationship with us, you have the right to receive information about our sharing of your personal information with affiliated entities or non-affiliated third parties for direct marketing purposes. If you wish to exercise these rights, please send your written request, via email or postal mail to “Shine the Light Disclosure” in the subject line. Please include your full name, street address, city, state and zip code in the body of your request. Our contact information is:

Attn: Privacy and Legal Department

Equity Street Capital, LLC

3033 Bunker Hill St.

San Diego, CA, 92109

Email: support@equitystreetcapital.com

We will not accept requests via the telephone or facsimile. We also may not be able to respond to requests that are not labeled or sent properly, or do not have complete information.

Do Not Track Disclosure

We do not collect or respond to Do Not Track signals and our websites do not function differently based on any Do Not Track preferences that may be received. For more information on Do Not Track signals, please visit https://allaboutdnt.com/

California Consumer Privacy Act

The California Consumer Privacy Act affords California consumers certain rights over their personal information (subject to certain exceptions). If you are a California resident, please review the California Consumer Privacy Act for information on your rights under California law.

How Will I Know if This Policy Changes?

Please check our Privacy Policy periodically for changes. We may change this Privacy Policy by notifying you of such changes by any reasonable means, including by posting a revised Privacy Policy on the website.

Any changes to this Privacy Policy will become effective upon posting the revised Privacy Policy on the website. The “last updated” date above indicates when this Privacy Policy was last changed.