PULSE EQUITY PRIVACY NOTICE

Welcome! We are Equity Mgmt Labs, Inc., d/b/a Pulse Equity. This Privacy Notice explains how Equity Mgmt Labs, Inc. (“Pulse Equity”, “Company”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites (the “Sites”) and other websites we own and operate that link to this Privacy Notice, and the related content, platform, services, products, and other functionality offered on or through our services (collectively, the “Services”). It does not address our privacy practices relating to Pulse Equity job applicants, employees and other personnel.

Except as otherwise provided below, Pulse Equity is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.

Personal Information we Process on behalf of our Clients

Data protection laws sometimes differentiate between “controllers” and “processors” of Personal Information. A “controller” determines the purposes and means (or the why and the how) of processing Personal Information. A “processor,” which is sometimes referred to as a “service provider,” processes Personal Information on behalf of a controller subject to contractual restrictions.

Pulse Equity provides equity management and other services, enabling streamlined communication, transparency, and trust-building among partners, driving higher retention. As part of our business relationship with our clients, we may collect, receive, gather, store, analyze, or otherwise process information on behalf of our clients, which may include Personal Information such as identifiers (e.g., name, mailing address, phone number, Social Security Numbers, date of birth, and email address), financial or other customer account information (e.g., bank account numbers, credit card numbers, billing address), commercial data (e.g., purchase history), online identifiers, biometric information (e.g., facial scans), and other personal information. We may collect this information from our clients, directly from you when you provide such information to us, or from other third parties on behalf of our client. We refer to this type of information and Personal Information as “client data.” When we process client data, we generally act as a processor. This means we process client data on behalf of our customers in accordance with the services we provide and subject to any applicable restrictions set forth in our contracts with them and under applicable laws. We do not control our client’s privacy and data security practices, which may differ from those in set forth in this Privacy Notice, and this Privacy Notice does not apply to client data we receive from you, from or on behalf of our clients or their agents, or from other third parties. If your Personal Information was submitted to us by, or on behalf of, a client and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable client with which you have a customer relationship directly.

If you are using with this Service because we have contacted you on behalf of our clients, the Personal Information we may collect, receive, process, and store directly from you may include Personal Information such as identifiers (e.g., name, mailing address, phone number, Social Security Numbers, date of birth, and email address), financial or other customer account information (e.g., bank account numbers, credit card numbers, billing address), commercial data (e.g., purchase history), online identifiers, biometric information (e.g., facial scans), and other personal information, and other information identifiable to you; your history on our site; a log or history of your communications with us (including chat history); geolocation data; and automatically collected information such as IP addresses and the type of device or operating system. You can also upload additional content to the Service, which may include your Personal Information. We may combine the information provided by you with other Personal Information we have received from our clients or other third parties.

Personal Information we Process under the GLBA

This Privacy Notice does not cover any personal information (“nonpublic personal information”) that we may collect or process pursuant to the Gramm Leach Bliley Act (“GBLA”) as a service provider to our financial institution clients. To learn more about privacy practices related to GLBA, please refer to the U.S. Consumer Notice provided by the financial institution with which you have a relationship for information about how they engage processors, like us, to process nonpublic personal information on their behalf.

1. I.  WHAT IS PERSONAL INFORMATION?

   When we use the term “personal information” in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular natural person or household or any other data or information that constitutes “personal data,” “personal information,” or “personally identifiable information.”

2. II.  OUR COLLECTION AND USE OF PERSONAL INFORMATION

   We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for the Services, make an online purchase, post a comment, send us messages, subscribe to our mailing lists, newsletters, or other forms of marketing communications, submit a job application, or use some other feature of our Services.
   
   We may link or combine your activities and information collected from you on our Sites and mobile apps with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.

Personal Information Collected from You

We may collect the following categories of personal information submitted to us by you through the Services:

• Contact Information

  Including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.

• Identification and Biometric Information

  including Social Security Number and full date of birth, and facial patterns and documents containing your photograph. From time to time when you are using the Services, we may request access to certain features of your smartphone or mobile device, such as facial recognition data and other data collected by imaging technologies provided by your camera or mobile device (collectively, "Facial Recognition Data"). We use this information, including Facial Recognition Data, to conduct Know Your Customer activities and to verify your identity as required under applicable laws. We do not retain Facial Recognition Data after we have verified your identity.

• Account Information

  including first and last name, company name, employer, job title, business email address, user ID and password, profile information, affiliations, account balances, payment and purchase history information, and any other information you provide to us. We use this information to administer your account, provide you with the relevant service and information, communicate with you regarding your account and your use of the Services, and for customer support purposes. Please note we utilize Dwolla, a third-party provider, to process payments or facilitate fund transfers on our behalf. Use of Dwolla’s services may require that you accept the Dwolla Terms and Dwolla Privacy Policy. In no event does Pulse Equity facilitate distributions or transmissions of funds for or on behalf of our users.

• Payment Information

  If you sign up for one of our Services requiring payment (i.e., equity management subscriptions), we collect the information provided in connection with such payment. Depending on the type of Services, you may be able to pay via wire transfer, credit card, or check and we may collect the financial information associated with such payment (e.g., routing and account number, wire transfer information details). Please note that we use third-party payment processors, including Plaid, to process credit card payments made to us. As such, we do not retain any personally identifiable financial information in connection with credit card payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party processor. The payment processor’s use of your personal information is governed by their privacy notice. To view Plaid’s privacy policy, please click here.

• Inquiry and Communications Information

  Including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, to communicate with you, to enhance the services we offer to our users, and to manage and grow our organization.

• Newsletter, Marketing Emails, and Blog Information

  Including email address and applicable interests and communication preferences. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. If you wish to stop receiving email messages from us, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

• Information Collected Through the Use of the Services

  Including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of the Site (collectively, “User Content”). User Content and any information contained in the User Content, including personal information and metadata you may have included, is stored and collected as part of the Service. We use the User Content to provide you with the Service.

• Feedback Information

  We may collect feedback and ratings you provide relating to out Services. We use this information to communicate with you, to conduct market research, to inform our marketing and advertising activities, and to improve and grow our business.

• Other Information

  Information you provide to us online, by phone, or in person. We may use this information to respond to your request, provide you the requested services, and to inform our marketing and advertising campaigns.

Personal Information from Third Parties

We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual.

We may receive the same categories of personal information as described above from the following third parties:

• Pulse Equity Entities:

  We may receive personal information from other companies and brands owned or controlled by Pulse Equity, and other companies under common ownership with Pulse Equity.

• Your Employer / Company: 

  If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Services.

• Other Users or Individuals Who Interact with Our Services:

  We may receive your information from other users or other individuals who interact with our Services. For example, if you decide to invest with a certain fund manager or group, that user may provide us with your Personal Information.

• Social Media:

  When an individual interacts with our Services through various social media networks, such as when someone “Likes” us on Facebook or follows us or shares our content on Google, Facebook, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

• Service Providers:

  Our service providers that perform services solely on our behalf, such as survey and marketing providers and third-party payment processors, collect personal information and often share some or all of this information with us. The information may include contact information, demographic information, payment information, information about your communications and related activities, and information about your orders. We may use this information to administer and facilitate our services, your orders, and our marketing activities.

• Information We Receive from Authentication Services You Connect to Our Services:

  Some parts of our Services may allow you to login through an authentication service such as Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book and contacts, or other information. The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site. We use this information to operate, maintain, and provide to you the features and functionality of the Services. We may also send you service-related emails or messages (e.g., account verification, purchase confirmation, customer support, changes, or updates to features of the Sites, technical and security notices).

• Other Sources:

  We may also collect Personal Information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Pulse Equity commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Pulse Equity satisfies the requirements under applicable law.

Personal Information Automatically Collected

We, through our third-party providers, automatically collect information you provide to us and information about how you access and use the Services when you visit our services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.

We, and our third-party partners, use tracking technologies to automatically collect usage and device information, such as:

• Information About the Computer, Tablet, Smartphone, or Other Device You Use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.

• Information About the Way You Access and Use Our Services, for example, the site from which you came and the site to which you are going when you leave our Services, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other browsing behavior and actions you take on the Sites.

• IInformation About How You Use the Services, such as the pages you visit, the links you click, the ads you view and click on, the videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Services and may record your mouse movements, scrolling, clicks, and keystroke activity on the Services and other browsing, search, or purchasing behavior. These tools may also record information you enter when you interact with our Services or engage in chat features through our Services.

• Information About Your Location, such as general geographic location that we or our third-party providers may derive from your IP address.

• Analytics Information.  We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Sites and Services, and to improve the effectiveness of our Services, offers, advertising, communications, and customer service. We may also use this information and the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

Additional Uses of Personal Information

We may use personal information we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services you have requested, and to process transactions, including providing you with a white paper you have requested or an online product demonstration;
• Manage our organization and its day-to-day operations;
• Verify your identity and entitlement to products or Services when you contact us or access our Services;
• Register you for and provide you access to events and webcasts;
• Communicate with individuals, including via email, text message, social media, and/or telephone calls;
• Request that individuals complete surveys about our organization, organizations we partner with, and Services;
• For marketing and advertising purposes, including to market to you or offer you through email, phone, or text message information and updates on products or services we think that you may be interested in (where applicable, we may send you marketing messages if you have given us your consent to do so);
• Administer, improve, and personalize our Services, including by recognizing an individual and remembering their information when they return to our Services;
• Process payment for our Services;
• Facilitate customer benefits and services, including customer support through our command center services;
• Identify and analyze how individuals use our Services;
• Conduct research and analytics on our customer and user base and our Services;
• Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
• Test, enhance, update, and monitor the Services, or diagnose or fix technology problems;
• Help maintain the safety, security, and integrity of our property and Services, technology assets, and business;
• Enforce our Terms of Use to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Prevent, investigate, or provide notice of fraud or unlawful or criminal activity;
• Comply with contractual and legal obligations and requirements;
• Fulfill any other purpose for which you provide personal information; and
• For any other lawful purpose, or other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.

1. III.  OUR DISCLOSURE OF PERSONAL INFORMATION

   We may share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

   Information About the Computer, Tablet, Smartphone, or Other Device You Use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.

Pulse Equity Entities:

We may share personal information with other companies owned or controlled by Pulse Equity, and other companies under common ownership with Pulse Equity, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.

Your Employer / Company:

If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.

Marketing Providers:

We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.

Customer Service and Communication Providers:

We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.

Other Service Providers:

In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.

Other Users:

With your consent, we may share your personal information with your investment partners.

Business Transaction or Reorganization:

We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

Legal Obligations and Rights:

We may disclose personal information to third parties, such as legal advisors and law enforcement:

• in connection with the establishment, exercise, or defense of legal claims; 
• to comply with laws or to respond to lawful requests and legal process;
• to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
• to detect, suppress, or prevent fraud;
• to protect the health and safety of us and others; or
• as otherwise required by applicable law.

With Your Consent:

We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.

1. IV.  CONTROL OVER YOUR INFORMATION

   You may control your information in the following ways:

   Access to Your Device Information.

   You may control the Services’ access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Services to access your network devices and geolocation and to integrate with your other applications.

   Email Communications Preferences. 

   You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).

   Push Notifications.

   You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.

   SMS Text Messaging. 

   You may opt-out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from receiving SMS texts from Pulse Equity directly relating to your use of the Services, such as for account login (e.g., we may send you a security verification code). To unsubscribe from promotional SMS texts, you can reply STOP to any one of our promotional text messages. For more information, see our Terms of Use.

   Modifying or Deleting Your Information.

   If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at legal@pulseequity.com. We may not be able to modify or delete your information in all circumstances.

   Cookies:

   If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

2. V.  DATA RETENTION

   Pulse Equity does not knowingly collect Personal Information from individuals under the age of 18 years. Our Sites are not intended for use by anyone under the age of 18 years. If we become aware that an individual under the age of 18 years has provided us Personal Information, we will take steps to delete such Personal Information without undue delay.

3. VII.  EMBEDDED LINKS TO THIRD-PARTY WEBSITES OR SERVICES

   Our Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notic

4. VIII. UPDATES TO THIS PRIVACY NOTICE

   We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

5. IX. CONTACT US

   If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to legal@pulseequity.com.

6. X.  STATE-SPECIFIC DISCLOSURES

   We may choose or be required by law to provide different or additional information relating to the processing of personal information (as defined below) about residents of certain countries, regions or states. Please refer below for additional information that may be applicable to you:

7. CALIFORNIA

   Shine the Light Disclosure. The California "Shine the Light" law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes.

8. ILLINOIS AND TEXAS

   Biometric Disclosures. For residents of Illinois or Texas, if we require you to provide us with any document that contains your photograph or if you need to verify your identity by providing a photograph or video of yourself, we will only use such data to verify your identity. Once you verify your identity, any photograph or biometric identity will be deleted.