We are committed to maintaining the confidentiality, integrity and security of information about our users, and we endeavor to take reasonable steps (including physical, electronic and procedural measures) to protect any data or other information collected via the Site or in providing our Services. Please note, however, that we cannot guarantee that the data or information collected may not be accessed, disclosed, altered or destroyed by breach of one or more of our safety measures. No Internet, electronic transmission or electronic storage of information is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us. Please keep these risks in mind when disclosing Personal Data (as defined below) to us.
Remember that your use of Parallel’s Services is at all times subect to the Terms of Service, which incorporates this Policy. Any capitalized terms used herein but not defined have the definitions given to them in the Terms of Service. This Policy includes additional notices that may apply to you if you are a California consumer. Please see the section further below titled “Your California Privacy Rights” for more details.
We collect information about you in a number of ways, including information you give us, information we get from others and information that is automatically collected.
Information We Collect From You
We may collect, among other things, your name, postal address, email address, phone number, username, password, demographic information, your occupation status and title, social security number, tax id number, birthdate, various tax forms, bank account information, credit reports, suitability responses, government identification, corporate documentation, liabilities information and other information you directly give us. We distinguish between (i) data that does not individually identify you but may include tracking and usage information about your general location, demographics or use of one of our products (“Non-Personally Identifiable Information”) and (ii) data that can be used to contact, locate or identify you specifically, either by itself or when combined with other sources that are easily accessed (“Personally Identifiable Information” and, together with Non-Personally Identifiable Information, “Personal Data”). By submitting or making available Personal Data through our Services, you agree to the terms of this Policy and you expressly consent to the processing of Personal Data in accordance with this Policy. We do not intentionally gather or process Personal Data about individuals who are under the age of 18. If we inadvertently hold or have access to Personal Data about anyone under 18, please let us know so we can delete it. For customers who have paid for software services, we collect your billing details such as credit card information, banking information, and/or billing address.
Information We Collect From Others
We may receive Personal Data about you from other sources like online investing platforms, your employer, credit reporting agencies, data aggregators, banks, brokerages, entities with which you are affiliated (for example, an entity in which you have invested) or other third party vendors in connection with our Services (our “Partner Companies). Our Partner Companies may supply us with Personal Data, including items such as your name, email, mailing address information, accreditation status (including supporting documentation such as tax or other documentation), social security number, tax identification number, bank statements, brokerage statements, securities holdings information (including subscription documentation), credit reports, liabilities statements and your login credentials for such Partner Company’s website or service, in order to help us provide the Services. We may add this information to the information we have already collected, or will in the future collect, from you in order to perform and improve the Services. In addition, as a side effect of our processing of Personal Data generally through the Services, we may receive further Personal Data regarding you from various information service providers utilized by the Services.
Information We Collect Automatically
Finally, we collect information from you, which may include Personal Data, when devices access our Site and Services. Some examples of the information we collect include: type of device, geographic location, IP address, domain name, what operating system is used, application information, unique devices, crash data and date/time stamps for your visit. The type of information we collect depends on the type of device used and its settings. We may automatically log information about you and your computer. For example, when visiting our Site, we log, among other things, your computer operating system type, browser type, browser language, pages you viewed, how long you spent on a page, location, access times and information about your use of and actions on our Site. We may also use industry standard identifiers and trackers (including cookies and their equivalents) (“Identifiers”) and navigational data like Uniform Resource Locators (URL) to gather information about you and your activity.
How We Use the Information We Collect
We use your Personal Data and other information we collect (collectively, the “Data Set“)in a number of ways. A non-extensive list of the ways we may use the Data Set is as follows:
- We use the Data Set to operate, maintain, and improve the Site, products, and Services. This includes use of other information to support delivery of the Services, assist with service request, monitor for errors, remedy security or technical issues, analyze website and application performances.
- We use the Data Set to respond to comments and questions, verify permission access, and provide customer service.
- We use the Data Set to setup your user account, correspond with you, and otherwise enable and facilitate your usage of our services.
- We use the Data Set to help you assert investor credentials and otherwise participate in securities transactions.
- We use the Data Set to assure us, and parties to transactions, of the validity of any information provided to us about you.
- We use the Data Set to verify your identity, investors credentials (e.g., your status as an accredited investor or qualified purchaser, your investing history, etc.), conduct and process diligence checks, and establish your investor credentials, eligibility and suitability for investment.
- We use the Data Set to facilitate your and our compliance with various laws, regulations, and industry oversight pertaining among other things to banking, financial information, securities transactions, money laundering, terrorism, and “know your customer” rules promulgated, among other things, by the U.S. Securities Exchange Commission and the Financial Industry Regulatory Authority.
- We use the Data Set to protect against fraud, site misuse, privacy and security breaches, securities and other legal violations, and to fulfill and enforce agreements reached with you and others.
- We use the Data Set to send information including confirmations, invoices and billing, technical notices, updates, security alerts, and administrative messages.
- We use the Data Set to communicate system updates, upcoming events, and other news about products and services offered by us. We may contact you to inform you about important services-related notices, such as privacy and policy update notices or changes in our terms of service. These communications are strictly necessary and you may not opt out of them.
- We use the Data Set to link or combine user information with other personal information. An example is when we combine the information a company has provided about their shareholders with the information entered by shareholders in their personal portfolios to improve the user experience.
- We use the Data Set to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
- We use the Data Set to provide and deliver products and service customer requests. An example is when an online investment platform calls our API to obtain information about a potential investor.
In addition, we process your Personal Data in a number of ways. As a general rule, we do not share Personally Identifiable Information without your express consent (reserving all rights to share in the circumstances outlined below). We do, however, share aggregated information or anonymous Identifiers with various third parties at our sole discretion. A non-exhaustive list of the ways we may share your Personal Data is as follows:
- We may share Personal Data when authorized by you, such as communicating your accreditation status, investor credentials, profile information, relevant documentation or other materials.
- We may share Personal Data in compliance with any applicable law.
- We may share Personal Data for legal, protection, information security and safety purposes. Examples include enforcing contracts or policies, reporting on security breaches or assisting with investigating and preventing fraud or security issues.
- We may share Personal Data to comply with laws and regulatory requests. Examples include responding to lawful requests and legal or regulatory processes.
- We may share Personal Data with those who need it to do work for us. For example, we may grant a Parallel employee or third party vendor the necessary access in order to review submitted documentation and verify identity or other credentials.
- We may share aggregated or anonymized data in any manner that we deem desirable. We may disclose or use aggregated or anonymized data for any purpose, including to analyze customer traffic, optimize content and advertisements, track conversions and remarket to persons who have taken certain actions. An example would be for highlighting relevant new deals from Partner Companies for you.
- We may use Identifiers to remember that you have visited our Site before (meaning we can identify the number of unique visitors we receive), customize elements of any promotional layout and/or content of the pages of the Site and Services and collect anonymous statistical data about how you use the Services (including time spent on the Site) and where you have come to the Site from, so that we can improve the Site and our Services and learn which parts of the Sites and Services are most popular with our users.
- We may also use Identifiers, or allow our Partner Companies to use Identifiers, to monitor conversion rates, click-through rates and similar anonymized user information.
- We may strip Personally Identifiable Information from data that renders the information personally identifiable (“Anonymous Data”). We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content and functionality of our Site and Services. We also may use this data for the benefit of third parties in our sole discretion.
- We will not share Personal Data with investors of the Company beyond any Personal Data that such investors are entitled to for customary legitimate business purposes.
- We may share Personal Data with third parties when we have consent to do so.
- We may engage third party companies or individuals as service providers to process information, support our Services and/or perform certain functions on our behalf, including, but not limited to, hosting, content syndication, content management tools, social media integration, marketing, analytics, billing and customer service. These entities may have access to Personal Data if needed to perform their functions. If such access is required, the third parties will be obligated to maintain the confidentiality and security of that Personal Data. They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to the Company.
- Customers may authorize access to customer data to third parties. An example is when a company grants their lawyers access for 506(c) diligence requirements.
- We affiliate with service providers who help us with security, fraud prevention, marketing technology, information technology, site analytics, site maintenance, software development, electronic signatures and other Site and service features, provided that all such parties will be under confidentiality duties to protect and not share any Personal Data we give them.
- We may share Personal Data as needed with our own service providers such as our accountants, lawyers, auditors, information technology staff, payment providers, financial institutions, and advisors.
- We may create, acquire, or otherwise partner with parent, subsidiary, or affiliate business entities, trusts, or other business entities for purposes of offering Services. These entities may use Personal Data under and consistent with the terms of this Policy.
- Although we sometimes refer to third party affiliates as “we” or part of the Services, please be aware that some of these entities are not under common ownership with, or controlled by, Parallel. All securities transactions (including any solicitation, engagement, brokering, closing, and clearing Transactions) are handled by third-party platforms or other broker-dealers. Further, per the terms of the transactions and other agreements you may enter into, Parallel may setup or contract with third parties to service, pool, and otherwise manage the securities that are the subject of the Transactions.
How You Can Access or Change Your Personal Data
Parallel understands that you may want to change, access or delete your Personal Data. Under certain circumstances, you may do so by accessing your profile yourself or by contacting us via email. Please note that all data used in the operation of Parallel becomes our sole property and can be used at our sole discretion. To protect your privacy and security, we may verify your identity before granting access or making changes to your Personal Data. For security reasons, and for other reasons at our sole discretion, Parallel will have no obligation to respond to inquiries with respect to Personal Data.
Your California Privacy Rights
This section provides additional details about the Personally Identifiable Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (“CCPA”).
Please see above for the types of information we collect, the business and commercial purposes we use that information for and how we share or disclose that information with certain third parties. We do not sell (as such term is defined in the CCPA) the Personally Identifiable Information we collect (and will not sell it without providing a right to opt out). Please note that we do use third-party cookies for our advertising purposes.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of Personally Identifiable Information we collect (including how we use and disclose this information), to delete their Personally Identifiable Information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at email@example.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
Important – Transfer of Data to the US of European personal information
Information that any European users submit to us is stored on servers located in the United States of America and may be transferred by us to our other offices and/or to the third parties (such as our Partner Companies) as described above, who also may be situated in the United States of America or elsewhere outside the European Economic Area (“EEA”) and may be processed by staff operating outside the EEA. The US and other non-EEA countries do not have similar data protection laws to the European Union, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe. Where we transfer your information, we will take all reasonable steps to ensure that your privacy rights continue to be protected consistent with our obligations under local law. By submitting information via our Site and Services, you agree to this storing, processing and/or transfer.