Effective Date: February 15, 2019
Collection of Information
Information You Provide to Us Directly
We collect information you provide directly to us. For example, we collect information when you interact with us as an investor, prospective investor, or former investor, when you create an account to access certain features of the Services, when you access or use any collaboration tools or participate in any interactive features of the Services, when you send us an email, fill out a form, respond to a survey, comment on a blog, register for an event, interact with us on social media, enter a promotional drawing, if any, or otherwise communicate with us. The types of information we may collect include the following:
- Contact information and personal details, such as your name, residential, business and postal addresses, telephone number, email address, and family details such as name of your spouse, partner or children;
- Profile information, such as the username and password you establish with the Services;
- Demographic details, such as date of birth, country of citizenship and/or country of residence, marital status;
- Information about your net worth and/or income, such as your stated net worth; stated current, historical, and expected future income; source(s) of income; and supporting documentation that you choose to submit (e.g., tax forms, tax returns, pay stubs, financial account statements, and information about your financial assets and liabilities);
- Government-issued identification (to the extent permitted under applicable law), such as a national identification number (e.g., a Social Security Number, tax identification number, or passport number), state or local identification number (e.g., a Driver’s License or other government-issued identification number), a copy of your government-issued identification card and related government issued photographs;
- Information about your investment experience and preferences, such as investment objectives, investment experience, liquidity needs, and risk tolerance;
- Financial Account and payment Information, such as your bank accounts you may use to source your investment funds, other related payment information and the cryptocurrency wallet addresses you may use to receive your RealTokens and revenue payout tokens, if any;
- Information about your relationship to a company, such as your current occupation, job title and whether you are a beneficial owner or authorized signatory of the legal entity using the Service;
- Feedback and correspondence, such as information you provide when you request information from us, receive customer support, or otherwise correspond with us, including by interacting with our pages on social networking online sites or services;
- Marketing information, such as your preferences for receiving marketing communications and details about how you engage with our marketing communications;
- Social media information such as username or handle, preferences; and
- Other information you choose to provide.
Information About Your Use of the Services
When you access or use the Services, we may automatically collect information about you, such as the following:
- Device Information: We collect information about the devices you use to access our website and Services, including the hardware model, operating system and version, unique device identifiers, network and mobile network information, and cryptocurrency wallet public keys.
- Log Information: We collect log information about your use of the Services, including your browser type and language, app version, access times, pages viewed, Internet Protocol (“IP”) address, approximate geographic location, and the webpage, IP address, or online service you visited before navigating to the Services.
Information We Collect from our Vendors
We may receive information about you from our vendors. For example, we use vendors to verify the identity and accredited investor status of users of our Services and perform KYC and AML checks. These vendors may provide us with information such as:
- Whether you or your company are on government lists of restricted persons (e.g., the OFAC list or other watch lists or sanctions lists);
- Whether there are adverse media reports regarding you or your company;
- Whether you or your company qualifies as a “politically exposed person” (e.g., a government official or representative of an international organization) under applicable law;
- Whether the personal information that you provided to us matches information contained in databases they consult; or
- Whether you are an accredited investor per applicable law.
The information we collect from vendors may include sensitive information (e.g., criminal conviction for fraud) to the extent permitted under applicable law.
Information We Collect from Third Party Vendors and Social Media Networks
Information We Collect from Other Sources
We may also obtain information from other sources such as public databases, publicly accessible government lists or media and internet searches and combine that with information we collect through the Services. For example, we may use information from LinkedIn to update information about you in our contact database or to verify your employment.
Use of Information
Internal Use of Information
We may use information about you for various purposes, including to:
- Operate, maintain and improve our website and the features and functionality of the Services;
- Manage identity verification of and perform KYC and AML checks on, and accredited investor status conformation of, our prospective investors;
- Process the investments you may make with our RealToken series issuers through the Services;
- Communicate with you regarding your account with us and your investments in one or more of our RealToken series investments;
- Respond to your questions, comments and requests;
- Provide information or services and send related information, including confirmations and receipts;
- Communicate about products, services, offers, promotions, rewards and events offered by RealToken or others we think will be of interest to you;
- Monitor and analyze usage, trends and activities related to, and the effectiveness of, the Services;
- Manage your online account(s) and send you technical notices, updates, security alerts, and support and administrative messages; and
- Notify you about any changes to the Services.
We may process and store information about you in the United States and other countries, which may have less protective data protection laws than the region in which you are situated.
Sharing of Information
We may share information about you as follows or as otherwise described in this policy:
- With vendors, consultants, professional advisors and other third-party service providers who are working on our behalf and either collect or need access to your information to carry out their work for us;
- In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including, for example, subpoenas and lawful requests by public authorities to meet national security or law enforcement requirements;
- If we believe your actions are inconsistent with our user agreements or policies, to protect the rights, property and safety of us or any third party, or to protect, deter or investigate against fraudulent, harmful, unauthorized unethical or illegal activity; and
- With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
Please note that information you post in your profile, blogs, listings, public or private groups, forums and any other interactive areas of the Services (if any) will be available to other users of those features and, in some cases, may be publicly available.
Links to Other Websites and Third-Party Content
We store the information we collect about you for as long as is necessary for the purpose(s) for which we collected it and in accordance with our legal obligations and legitimate business interests or internal policy requirements. To help us do this, we apply criteria to determine the appropriate periods for retaining your personal data depending on its purpose, such as proper account maintenance, RealToken investment record keeping, facilitating client relationship management, and responding to legal claims or regulatory requests.
RealToken is extremely aware of the need to protect your personal data against loss and unauthorized manipulation, access or modification. To protect your personal data, we employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our website and the Services. These measures are designed to appropriately protect personal information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal information in our possession. We will continuously assess and change our internal procedures accordingly to meet data protection requirements; however, no security system is impenetrable and, although we intend to do our best to protect your personal data, we cannot guarantee the security of our systems or your personal information. You agree to not hold us and our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided by you through our website or Services.
Residents of the European Economic Area
You may update, correct or delete your online account information (if any) at any time by logging into your account. If you delete any account information, we may retain certain information as required by law or for legitimate business purposes.
You may opt out of receiving marketing or promotional emails from us by following the instructions in those emails. Please note that even if you opt out of receiving promotional emails, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Information Collected Via Cookies
You may determine not to accept cookies by following the following procedures which most web browsers support: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. By blocking or disabling cookies, your experience using our website may be negatively impacted, as some features and services on our website may not work properly once our cookie is disabled. Depending on your mobile device and operating system,
You may also write us at:
2750 NE 185th street, suite 306.
Aventura, Florida 33180
Attn: Legal – Privacy