Last Updated on July 22, 2021
We reserve the right to change this Policy at any time. We will notify you of material changes to this Policy by sending notice to the primary email address specified in your account or by a prominent notice on our website. Changes and clarifications will take effect immediately. You should periodically check our website, including the page on which this Policy is located, for updates. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use and/or sharing of your Personal Information is subject to the updated Policy.
What Information Do We Collect?
Information Provided by You
We collect information that you knowingly give us when you create an account, contact us or otherwise access or use our Services. This may include:
- Your full name, email address, residential address, citizenship, telephone number, social security number, date of birth, employment information (including status and employer information, if applicable), information regarding investor “accreditation” and suitability, responses to surveys that we may ask you to complete for research purposes or to help direct FranShares activities and social media account information;
- The contact information of your representative, if any; and/or
- Details of any financial transactions you participate in on the Services, including the amount, currency and method of payment.
Information Collected Automatically
We automatically or passively collect information when you access or use our Services. This may include:
- Device type used to access our website (i.e., computer or mobile device), unique number assigned to identify such device, your device’s operating system, your device’s application version and your device’s internet protocol (IP) address;
- Whenever you visit or interact with our website, information about how our website is accessed and used, including, but not limited to, click path taken through our website, your use of features or applications on our website and/or other publicly available information; this data is generally non-identifying, but, if we associate it with you as an identifiable person, we will treat it as Personal Information; and/or
- If you access our Services from a mobile device, your device’s unique mobile platform advertising identifier, such as Apple’s “Identifier for Advertising ID” or Google’s “Android Advertising ID” (“mobile advertising identifiers”), and the ways you use the Services.
How Do We Use the Information We Collect?
We use the information we collect to:
- Deliver and improve the Services and your overall user experience;
- Protect against, investigate and deter fraudulent, unauthorized and/or illegal activity;
- Link or combine user information with other Personal Information;
- Compare and verify information for accuracy and update our records;
- Validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols;
- Email, text message, message or otherwise contact you with information and updates about us and the Services, and respond to your comments and questions if you’ve provided us with the means to do so;
- On a de-identified, aggregated basis, analyze how you use the Services with tools like Google Analytics to help us understand traffic patterns and know if there are problems with the Services; and/or
- Create targeted advertising to promote the Services and engage our users.
Do We Share Your Personal Information?
We do not rent, sell or share your Personal Information with third parties except with your consent or as necessary to complete any transaction or provide any service you have requested or authorized in this Policy.
In connection with the Services, we may provide your Personal Information to the following third parties:
- Partners: Sometimes we collaborate with others, including our broker-dealer, to deliver the Services, and may provide such Personal Information as required by our partners who do not have an independent use of the information we disclose to them.
- Affiliates: We may share your information with our affiliates and/or subsidiaries.
- Service providers: We work with a wide range of third-party service providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, identity verification services and other non-governmental organizations, and may provide such information as required by any such service provider in connection with the performance of the applicable service.
- Payment providers: We work with payment providers such as Stripe, Dwolla and Plaid to facilitate the payment process in the Services. These providers will store certain information about you.
We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Services; and/or to protect our rights or property. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes. Any third party with whom we share your data with will be required to provide the same or equal protection of such data as stated in this Policy.
The manner in which partners, service providers and payment processors use, store and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s).
How Do We Use Tracking Technologies?
Even if you are only browsing the Services, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Services) is automatically collected. This information will be collected every time you access the Services and will be used for the purposes outlined in this Policy.
Web beacons, also known as pixel tags, may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow. Our third-party advertising service providers may also use web beacons to recognize you when you visit the Site or access the Services and to help determine how you found the Services. If you would like more information about this and to know your choices about not having this information used by these companies, please visit: the Digital Advertising Alliance’s website, https://www.aboutads.info/, or the Network Advertising Initiative’s website, https://networkadvertising.org/consumer/opt_out.asp.
How Do We Secure Your Personal Information?
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser, including by signing off after you have finished accessing your account.
We are committed to safeguarding the confidentiality of your information but cannot guarantee the security of your information. We provide physical, electronic and procedural safeguards to protect information we process and maintain. For example, we (a) encrypt any information we store, (b) transmit information via https and (c) limit access to this information to (i) authorized employees and contractors who need to know that information in order to operate, develop and/or improve the Services and (ii) third parties that must receive that information in order to facilitate provision of the Services. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. Unauthorized entry or use, hardware or software failure and/or other factors may compromise the security of user information at any time. If you believe your information may not be secure for any reason, please contact us immediately at email@example.com.
Your Choices Regarding Information
You have several choices regarding the use of Personal Information on the Services.
Changing or Deleting Your Personal Data
All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at firstname.lastname@example.org or, in certain cases, by accessing your user account. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your Personal Information, then your user account will be deactivated. If you wish to cancel your account, you may do so by emailing email@example.com, and any Personal Information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law, subject to our data retention policy.
We retain information we receive for as long as you use the Services or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Download or Access Personal Information
You can ask us for a copy of your Personal Information, including a copy in machine readable form, by emailing us at firstname.lastname@example.org.
Opting Out of Email Communications
We may use some of the information we collect for marketing purposes, including to send you promotional communications about new features, products, events or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at email@example.com to opt out.Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this Policy.
Links to Third-Party Websites
How We Respond to Do Not Track Signals
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from your browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.
- For iOS devices with iOS 7 or higher: open Settings > select Privacy > select Advertising > enable Limit Ad Tracking; and
- For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: open the Google Settings app > select Ads > enable Opt out of interest-based advertising.
Please note, however, that opting out of mobile advertising identifier collection may prevent certain Services from functioning properly.
Third-Party Direct Marketing
We do not share personal data with third parties for their direct marketing purposes without your consent.
A Note to Users Outside the United States
FranShares is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
We do not use the Services to knowingly solicit data from, or market to, children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at firstname.lastname@example.org. We will delete such information from our files within a reasonable time.
California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business with which the California resident has an established business relationship what types of personal information, if any, the business shares with third parties for direct marketing purposes by such third parties and the identities of the third parties with whom the business has shared such information in the immediately preceding calendar year. To access this information, please contact us by email at email@example.com.
If you have any questions about this Policy, your Personal Information, or the Services, you can contact firstname.lastname@example.org.