Privacy Policy

Introduction

This Privacy Policy applies to Fluidity Factora Inc. and each of its affiliates, including, but not limited to, Fluidity Factora Administration and Servicing LLC and Propellr Securities LLC (collectively, “Factora”), and outlines the types of personal information Factora collects on this website (factora.io), why it collects it, how it uses it and what choices you have regarding its collection and use of this information. Privacy is important to Factora and it works hard to protect your personal information and ensure that it is kept private and secure. If you have any questions or if you believe that Factora has not adhered to this Privacy Policy, please send Factora a note at support@factora.io.

Summary

Factora operates this Website. Factora collects personal information from you when you visit factora.io, register with Factora and become a customer of Factora. In addition, as a U.S. broker-dealer, Propellr Securities LLC (see Broker Check) is required to collect certain information in order to allow you to invest in its transactions. Factora uses aggregated personal information to improve, monitor and protect the security of this Website. Factora does not share, sell, rent or trade your personal information except as provided in this Privacy Policy, with your consent, or as required by law. If you are not comfortable providing personal information to Factora, then this Website will not be useful to you and you will not be able to do business with Factora.

How You Accept This Policy

By using and continuing to use this Website, you agree to this Privacy Policy and any updates as well as the electronic delivery of information. If you do not agree with the terms set forth in this Privacy Policy, please do not use this Website. Our Terms and Conditions take precedence over any conflicting Privacy Policy provision.

As A Visitor

Factora collects various types of anonymous information about visitors to the Website, such as device-related information (e.g., browser type, IP address) and server log information (e.g., date and time of day of your visit). And Factora also collects information that you input into this Website to become a customer or otherwise.

As A Customer

When you register with Factora or become a customer, Factora will collect certain personal information, including your full legal name, email address, permanent address and date of birth. In order to provide financial services, Factora is also required to collect certain additional information, including your social security number, driver’s license number or other government issued identification, tax identification, income, place of employment, financial status, investor experience and preferences, information provided as part of past transactions involving Factora, information from consumer reporting agencies or other non-affiliated parties and other non-public materials needed to ensure compliance with securities laws and know your customer and anti-money laundering requirements. You may choose not to provide this information, but you cannot become a customer without providing it. When you subscribe for an offering, you may also be asked for bank account information and your digital wallet address to originate transfers and make disbursements to you.

How We Use Your Personal Information

Factora uses personally identifiable and other collected information in a manner that is consistent with this Privacy Policy. Factora uses your personal information to enhance your Website experience, create, operate and maintain your account in accordance with U.S. law, monitor and protect the security and integrity of this Website, and better market and advertise its services.

As part of this process, Factora may from time to time aggregate some of your personal information in certain data analyses, reports or other interpretations of investment trends for both internal and external purposes. When aggregating personal information, Factora makes sure that the information is not identifiable to any particular visitor.

By registering with any part of the Factora website you agree to become a customer of Factora and its affiliates.

When We Share Your Information

Factora does not sell, rent or trade your personal information with any third parties without your consent or as required by law. In order to provide financial services, Factora may share your personal information with financial service providers, non-financial companies, and other third parties, such as consumer identification verification services, public accounting firms and other service providers, for the purpose of serving you as a customer, complying with regulatory requirements and advertising Factora’s services. Factora has entered into agreements that require that these third parties keep this information confidential.

Factora may also disclose personal information that it collects to companies that offer securities on its Website to enable participation in the offering.

Factora may disclose personal information in response to legal process or as permitted or required by law when it reasonably believe it is necessary or appropriate to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of Factora’s Terms and Conditions or other agreements.

Information about Factora’s users, including personal information, may be disclosed or transferred to entities now or in the future affiliated with Factora or as part of any merger, acquisition, change of control, debt financing, insolvency, bankruptcy or sale of Factora’s assets. Such information may be used in the businesses of any entities so receiving it.

If you choose to close your account or your account is terminated with Factora, Factora will continue to adhere to the privacy policies and practices outlined here.

Cookies And Pixels

Cookies are small pieces of data that are stored on your computer, mobile phone or other device. Pixels are small code blocks on a website that allow another server to measure how many views a webpage receives, and often are used in connection with cookies.

Factora uses these and other technologies in order to customize and improve your experience with the Website regardless of whether you become a customer. Cookies store anonymous information, such as whether you viewed the site from your mobile device. Factora may store some personal information in a cookie and/or pixel, such as the site that you visited immediately prior to visiting the Website, and relevant financial information that allows Factora to enhance your user experience and for marketing purposes.

Analytics Services

Factora uses analytics tools such as “Google Analytics” (collectively referred to as “Analytics Services”) to collect information about the usage of this site. These Analytics Services collect information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. Factora uses the information it gets from these Analytics Services only to improve this site.

Minors

This Website is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with Factora or provided Factora with personally identifiable information, please contact us at support@factora.io. Additionally, if Factora becomes aware at any point that a child under the age of 18 is using its services, Factora will terminate the account.

How You Can Access Or Change Your Personal Information That Factora Has Collected

Once you have registered with Factora, you can access your profile, review the information that is stored and revise that information. If you have any problems, you may contact Factora at support@factora.io. Due to U.S. regulatory requirements, Factora does not delete residual copies of outdated information and must preserve all customer data for a minimum of six years.

Protection Of Personal Information

Factora works diligently to protect your personal information. Factora employs several physical and electronic safeguards to keep your information safe. Factora uses industry standard browser encryption, stores all of its data on servers in secure facilities, and implements systematic processes and procedures for securing and storing data. Factora limits access to your personal and financial information to only those employees with authorized access, and requires third parties who perform services for it to agree to keep your information confidential. Furthermore, if you choose to close your account or your account is terminated with Factora, Factora will continue to adhere to the privacy policies and practices outlined here. If you maintain an account that you access through this Website, you are responsible for protecting and maintaining the confidentiality of your account and password, and restricting access to your computer.

Changes To The Policy

Factora may modify this Privacy Policy over time by posting a new version, which is your responsibility to review. Any changes to the Privacy Policy will be reflected on this Website and will become effective immediately upon posting. Factora encourages you to periodically review this Privacy Policy to stay informed about how it is protecting the personally identifiable information it collects. Please check the effective date below to determine if there have been any changes since you last reviewed this Privacy Policy.

Your Rights As A California Resident

Residents of California have the right to request from Factora certain information with respect to the types of personal information Factora shares with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom Factora has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing Factora at support@factora.io. Your request should specify your full name and the email address you used when submitting personal information to Factora

Your Rights As A Vermont Resident

Factora does not share nonpublic personal financial information it collects 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 Factora at support@factora.io. Kindly note, however, that Factora will not be able to provide you with services without the ability to share this financial information.

International Visitors

This Website is hosted in the United States. If you are an international visitor, please note that by providing your personal information, you are: (i) permitting the transfer of your personal information to the United States, which may not have the same data protection laws as the country in which you reside; and (ii) permitting the use of your personal information in accordance with this Privacy Policy. Factora may also request additional documentation due to your status as a non U.S. citizen, for purposes of KYC/AML requirements and Factora’s own compliance processes.

The European Union’s General Data Protection Regulation and other countries’ privacy laws provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the United Kingdom’s Information Commissioner’s Office. As noted above, this Privacy Policy is intended to provide you with information about what personal data Factora may collect about you and how it is used. If you wish to confirm that Factora is processing your personal data, or to have access to the personal data that Factora may have about you, please contact Factora at support@factora.io. You may also request information about: the purpose of the processing; the categories of personal data collected; who else outside of Factora may have received the data from the Factora; what the source of the information was (if you didn’t provide it directly to Factora); and how long it will be stored. You have a right to correct the record of your personal data maintained by Factora if it is inaccurate. You may request that Factora erase the data or cease processing it, subject to certain exceptions. You may also request that Factora cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Factora processes your personal data. When technically feasible and at your request, Factora will provide you with your personal data or transmit it directly to another controller. Access to your personal data will be provided at no cost to Factora Website international visitors. If access cannot be provided within a reasonable time frame, Factora will provide you with a date when the information will be provided. If for some reason access is denied, Factora will provide an explanation as to why access has been denied. Please note that if Factora receives a request from you to exercise your rights, Factora may ask you to take reasonable steps to confirm your identity, including your residency within the EU or UK.

Opt-out Notice

If you would like to opt-out of any of the above terms, including the disclosure of your information to non-affiliated third parties of Factora, please contact Factora at support@factora.io.

Questions

If you have any questions about our Privacy Policy, please contact us at support@factora.io.

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