Effective Date: February 22, 2020
This Online Privacy Notice explains how IOI Capital and Markets, LLC and its subsidiaries and affiliates (collectively, “iownit,” “us” or “we”) collect, use, share, and protect personal information obtained when you visit www.iownit.us (the “Site”). This Notice also describes your choices regarding access to, and use and correction of, personal information that iownit maintains about you.
If you have questions regarding our processing of your personal information, you may email us at email@example.com or write to us at 8 Greenway Plaza, Suite 1515, Houston, TX 77046.
Collection of Information
We may collect personal information from you when you use the Site (e.g., when you sign up for an account, make an investment, verify your identity or accredited investor status, provide payment instructions, or send us an email through the Site). This personal information may include your name, phone number, email address, home or business address, birthday, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, information from your transactions with us (such as your account balance and account usage), or other information you provide or upload to the Site such as photographs, answers to questionnaires or surveys, or responses filled in on forms made available on the Site.
We also may automatically collect certain information about you when you visit the Site. This information may include, without limitation, websites , articles, presentation and videos viewed; time spent using certain features of the Site; data such as server locations, cookies existing on your computer, search criteria used, and results; date, time, connection speed; internet protocol (“IP”) address; and other similar analytic data. We collect this information using various technologies, including cookies and server logs. “Cookies” are pieces of information that may be placed on your computer by a website for the purpose of facilitating and enhancing your communication and interaction with that website. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about transactions with the server.
We use analytics programs and service providers, such as Google Analytics, which may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to track demographics, remarket, and improve user experience. To find out more about how third-party analytics services manage personal information in conjunction with delivering ads online, and how to opt-out of information collection by these networks, you may visit: http://www.youradchoices.com, http://www.aboutads.info/appchoices, and http://www.networkadvertising.org.
Google Analytics collects information including, but not limited to, the time of each of your visits to the Site, whether you have visited the Site before, what website referred you to the Site, and what pages you viewed on the Site. For more information on how Google Analytics uses data collected through the Site, visit: http://www.google.com/policies/privacy/partners/. To opt out of Google Analytics cookies, visit: http://www.google.com/settings/ads and https://tools.google.com/dlpage/gaoptout/.
Use and Sharing of Information
Consistent with this Notice, iownit may use information we obtain through the Site for various purposes, including to better serve you and enhance your experience on the Site. In addition, we may use your personal information (1) to market our products and services to you, (2) to provide services and products you request, (3) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of the Site and other services, (4) to meet any regulatory requirements for the offer or sale of securities required by law, rules, or regulations, (5) to engage in any other lawful activities we believe are consistent with the foregoing, and (6) to protect against legal liability.
iownit may make your information available on the Site and visible to other users of, or visitors to, the Site. For instance, subject to certain preferences and permissions, information you provide about yourself in response to questionnaires on the Site, such as information concerning your status as an accredited investor, may be made available to others. As such, other users of the Site may be able to personally identify you based on your information made available on the Site.
Your information also may be disclosed to our agents, vendors, consultants, marketing service providers, and other service providers who perform certain functions or services on our behalf. These third parties, companies, or individuals may have access to your information as needed to perform their functions or services. Examples of these services may include ID verification, accreditation/financial/credit verification, electronic document signing, payment processing, sending postal mail and email, escrow services, disbursement of funds, analyzing data, marketing assistance, and customer service.
iownit may also use and disclose your information to investigate and help prevent potentially fraudulent or unlawful activity; to protect the personal safety of individuals; to protect and defend our rights or property or the rights or property of others; to comply with legal obligations, including requests and orders from law enforcement, courts, or administrative agencies; or in connection with a financing, sale, merger, reorganization, or other transaction concerning iownit‘s business or assets. In the event that iownit may be sold or is sold to another company or entity, your information may be sold or transferred to such acquiring company or entity.
Third Party Websites and Services
This Site may contain links to other websites and services not maintained by iownit. In addition, other websites and services may reference or link to this Site. We encourage you to be aware when you enter or leave the Site and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.
Certain functionalities on the Site may permit interactions that you initiate between the Site and third parties, such as third-party social networks (“Social Features”). Examples of Social Features include the ability to log in using your third-party service account and enabling you to send content between the Site and a third-party service. If you use Social Features and other third-party services, information you post or provide access to may be publicly displayed on the Site or by the third-party service that you use. You should review the terms, policies, and settings of those third-party services to learn more or adjust your settings. Using Social Features may allow both iownit and the third-party service to access certain information about your use of our Site and theirs, including your personal information. In addition, if you utilize third-party services to log into the Site, other users you are connected to through such services may be able to view or follow information about you on the Site.
We may at times send you email communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional emails from us, you may unsubscribe by using the unsubscribe link at the bottom of such emails or by emailing us at firstname.lastname@example.org. Please note that opt-out requests may take up to one (1) week to process. Please also note that opting out of receiving promotional communications will not opt you out of receiving transactional messages, such as service or termination announcements or payment confirmations.
You may modify your account information through your profile page. You will be able to change your email address, password, contact information, or other log in information by visiting your account’s settings page. You also may set certain preferences and permissions regarding the visibility of your information to others. If you wish to delete your account or need help modifying account information, please contact us at email@example.com.
Your browser settings may allow you to clear cookies from your computer or stop or restrict the placement cookies by transmitting a “Do Not Track” signal to websites and online services you visit. Like many websites, this Site does not respond to “Do Not Track” signals received from a visitor’s browser.
Please note that, although you may still use the Site if you block or clear cookies from your computer, the removal of cookies may interfere with certain Site features and/or functionality.
As discussed above, you may also wish to use a Google Analytics opt-out web browser add-on. Information on this option is available at https://tools.google.com/dlpage/gaoptout/.
California Privacy Rights
California’s “Shine the Light” Law
California law permits customers in California to request certain details about how their personal information is shared with third parties and, in some cases, affiliates if that personal information is shared for those third parties’ and affiliates’ own direct marketing purposes. We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at firstname.lastname@example.org or:
8 Greenway Plaza, Suite 1515,
Houston, TX 77046
To make a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident, and provide your current California address to which we will send our response. Your inquiry must specify “California Privacy Rights Request” in the subject line of the email or the first line of the letter and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.
The California Consumer Privacy Act (CCPA)
California residents may have certain additional rights under the CCPA, such as the right to request a business that is subject to the CCPA to provide access to their personal information or delete their personal information, and the right to opt out of sales of their personal information. As iownit is not subject to the CCPA, we are not obligated to respond to CCPA requests. However, you may contact us by emailing email@example.com if you have questions regarding our processing of your personal information.
We employ appropriate administrative, technical, and physical safeguards that are designed to help protect personal information we obtain through the Site. Although we maintain reasonable procedures to safeguard personal information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the security of your information submitted online.
The Site is not intended for use by children under thirteen (13) years of age, and we do not knowingly solicit or collect personal information from children or teenagers. If we learn that we have received personal information from an individual under the age of 13, we will delete the information in accordance with applicable law.
Visitors from Outside the United States
The Site is maintained in the United States of America. If you are visiting the Site from outside the United States, please be aware that information we obtain through the Site will be processed in the United States or in other jurisdictions. By accessing the Site, you acknowledge and consent to the transfer and processing of your personal information in the United States and other jurisdictions, as described in this Privacy Notice. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other countries may be different from the laws in your country of residence.