Updated April 2020
Your Privacy is Important to Us
If you have any questions that this policy does not address, please contact us. By accessing the Services, registering as a user, using our Service or by otherwise submitting your personal information to us, you give your consent to the collection and use of personal information as explained in this policy.
The term “personal information” refers to non-public information that personally relates to or identifies you (such as your name, password, age, gender, email address, postal mailing address, zip code, home/mobile telephone number, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, website pages viewed and other similar information).
Non-personally identifiable information collected on the Website may include, without limitation, sites visited before visiting the Site, frequency of visits, clickstream data, browser type, operating system, organization name, articles, internet connection speed, presentations viewed, time spent viewing pages of our website or using certain features of our website, demographic data such as server locations, location services, cookies existing on your computer, search criteria and results, and other information which does not specifically identify you.
How we limit collection & use of data
We are required by law and regulatory bodies to ask for certain information in order to provide our Services to you. CrowdStreet makes commercially reasonable best efforts to maintain the confidentiality, integrity and security of our clients’ personal information.
Keeping client information secure, and using it only as our Users want us to, are matters of principle for all of us at CrowdStreet. With this in mind, here is our commitment to each and every User: Except as you may otherwise expressly approve, we will limit the collection and use of client and user information to what we believe would be useful to service your accounts, administer our business, or to tell you about our Services;
- We will restrict employee access to client and user information to those who need to know in order to provide Services to you;
- We will educate our employees according to our internal policies to reinforce the importance of confidentiality and client and user privacy;
- We will maintain commercially reasonable and customary security standards and procedures to protect information about you;
- and We will respond quickly to your request to correct inaccurate information.
How and Why We Gather Information
When you register for an account for the Services or at any later time, we collect certain personal information from you to open an account, transact business, communicate with you, verify your identity and fulfill legal and regulatory requirements. We call this your “Profile.” From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences.
A “web beacon” is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a site or in an email which allows the website to record the simple actions of the user opening the page that contains the beacon.
“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 any transaction you conduct with the server.
We or our service providers may also collect web surfing data related to your use of the Services (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences). This may be accomplished by using cookies, web beacons, page tags or similar tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Website. Web surfing data and similar information may be used for administrative purposes; to assess the usage, value and performance of our online products and services; and to improve your experience with the Services.
How Information Helps Both You and Us
CrowdStreet’s mission is to provide you with exceptional investment opportunities to match your individual investment goals. Information about you and your accounts plays a key role in our ability to succeed in this mission. It also helps us service your accounts and administer our business. For example, we use information about you to:
- Provide you with the Services available through the Website;
- Best determine which products and services may be of most interest to you;
- Establish and set up your account, issue an account number, and maintain your transaction history;
- Respond more accurately and efficiently to your requests;
- Identify opportunities to give you more convenience and control by developing new services that may benefit you;
- Better market and advertise CrowdStreet products and services;
- Verify your identity and contact information to help protect you and CrowdStreet from fraud;
- Comply with certain legal and regulatory requirements.
We generally use the information that you provide or that we collect to establish and enhance our relationship with you, and to operate, maintain, enhance, and provide the Services and the Website. We may use such information to periodically provide you with information, newsletters or offers about features and services available through the Services that may be of interest to you.
We may also send information or offers to groups of Users on behalf of other Users or third parties. However, you will have the option to opt out of receiving such information. We use aggregated information provided by or collected from our Users to understand and analyze the usage trends and preferences of our Users, to improve the way the Services and the Website work and look, and to create new features and functionality.
We may use aggregated information about our Users’ investments to generate statistics and maps that we deem helpful in the provision of the Services or any part thereof. We do not and will not sell analytics about our users without written consent from the user.
As you browse CrowdStreet and other websites, online ad networks we work with may place anonymous cookies on your computer, and use similar technologies, in order to understand your interests based on your (anonymous) online activities, and thus to tailor more relevant ads to you.
Sharing Your Information with Others
We may allow you to share certain information with other Users of the Services. You can share your profile with all other Users, or only with such other Users as are designated by you. You are not required to share your profile or any other information with other Users. If you do share your profile, anyone you designate will be able to see what companies you are following and investing in.
If you indicate an interest in making an investment through the Services, such as indicating an interest to buy equity or make a loan in a particular private real estate company, we will notify the party or parties offering the investment (the “Issuer”) of your interest and may notify other Users with whom you have chosen to share information. By indicating an interest in an investment and/or sharing your Profile with other Users, you consent to this disclosure of your information. We may also collect and store information, which could include Non-Personally Identifiable Information or Personally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.
Social Media Features
You can log in to the Website using services such as Linkedin or Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.
How and Why CrowdStreet Discloses Your Information to Third Parties
We limit the sharing of personal information outside CrowdStreet. We do not sell, license, lease, or otherwise disclose your personal information to third parties, except as noted below:
We may disclose your personal information when such disclosure is legally required or appropriate pursuant any court orders, subpoenas or any regulations, including responding to court orders and subpoenas, cooperating with government agencies, other regulatory bodies, and law enforcement officials, performing background checks, resolving disputes or performing risk-management functions.
To help us improve our services, we may engage third parties to help us to carry out certain internal functions such as information management, account processing, client services, or other data collection relevant to our business. Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us, such as data processing, marketing assistance, and companies that perform reporting, tax documentation, custody, title or escrow services on our behalf. Use of any personal information we share with these third parties is limited to the performance of the task we request
We will only transfer your personal information to trusted third parties who provide sufficient technical and organizational security measures and guarantees governing the use of your information. Where third parties process personal information on our behalf, they will be required to agree, by contractual means or otherwise, to process the personal information in accordance with the applicable law.
We may make certain automatically collected information about your interactions and activities on the Services, such as the business or investment areas of interest to you or that you have invested in, and your past activities, projects or proposals, publicly available on or through the Services. Any such publicly available information will be accessible by other Users.
In the event that CrowdStreet engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of CrowdStreet’s assets or stock, or other similar transaction or proceeding, it reserves the right to transfer or assign the information that it has collected from its Users in connection with, or in contemplation of, such activities, subject to standard confidentiality arrangements and applicable law.
Keeping Information Safe
We limit access to your personal information to those employees who have a legitimate business need to access such information to provide you with the Services. In keeping with industry standards and practices, we maintain commercially reasonable physical, electronic and procedural safeguards and controls to protect your information. The website is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.
Users are required to identify and authenticate themselves prior to accessing restricted portions of the Services. As a reminder, our platform supports two-factor authentication to protect your login. Generally, identification and authentication take place through the use of your user name and a password. You are responsible for keeping your password confidential. We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, notify us at email@example.com.
The transmission of information via the Internet is not completely secure, and for this reason we cannot guarantee the security of information sent to us electronically. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may also post a notice on or through the Website and the Services in the event of a security breach. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
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 at: http://info.crowdstreet.com/hs/manage-preferences/unsubscribe. Please note that opt-out requests may take up to twenty-four (24) hours to process.
Please also note that at times we may need to send you email communications that are transactional in nature, such as service or termination announcements or payment confirmations. You will not be able to opt-out of these communications.
However, you can always modify the information concerning your account by visiting your profile page and editing any information you wish to change. You will be able to change your email address, password, contact information, or other login information by visiting your account’s settings page subject to our website policy.
If you wish to delete your account or need help modifying account information, please contact us a firstname.lastname@example.org. We will require up to twenty-four hours (24) to process such requests. Through your account settings you will be able to set certain preferences and permissions regarding the visibility of your information, including Non-Personally Identifiable Information or Personally Identifiable Information, to others.
You may stop or restrict the placement of CrowdStreet’s cookies, Google’s cookies and third party cookies on your computer by adjusting your web browser preferences or a “Do Not Track” setting in your web browser. If you do so, you may still use our website, but this may interfere with some of its functionality. You may also clear cookies from your computer via your web browser settings. You may also wish to use a Google Analytics opt-out web browser add-on.
If you would like us to remove your Personally Identifiable Information from our database, please send a request to: email@example.com. We are not responsible for removing your Personally Identifiable Information from the lists of any Third Party Services or other third party who has previously been provided your information in accordance with this notice.
Reviewing, Changing or Correcting Information
An Ongoing Commitment to Your Privacy
The CrowdStreet website is not intended for use by children, especially those under eighteen (18) years of age. No one under eighteen (18) years of age is allowed to use the website, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children under eighteen years of age. If you believe that a minor has disclosed Personally Identifiable Information to CrowdStreet, please report this to us at: firstname.lastname@example.org.
For citizens of the European Union, please contact email@example.com for requests and inquiries regarding the data retained and managed by this portal and your rights to be forgotten related to the General Data Protection Regulation (GDPR).