Privacy and Cookie Policy

LAST MODIFIED: SEPTEMBER 2018

This Privacy and Cookie Policy (this “Policy”) describes the ways in which InvestNext, LLC (“InvestNext”) collects, uses, and discloses information about you, including personally identifiable information, in connection with your access to the website accessed via https://www.investnext.com (the “Website”) and the information, content and features provided through the Website (the “Services”). Throughout this Policy, “you” refers to the individual or entity that is visiting the Website. By accessing the Website, you consent to the use of your information as set forth in this Policy. If you are a customer of InvestNext or an end user accessing an investor portal, additional and/or different privacy terms may apply to you, as indicated at the time you set up an account to access the restricted portions of the Website.

This Policy

1. Scope. InvestNext provides you access to the Website and the Services, subject to the Website’s Terms of Use. In the course of providing access to the Website and the Services InvestNext may collect “Personal Information,” which means any information relating to an identified or identifiable natural person (a “data subject”) (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person). InvestNext does not collect your Personal Information except to allow you to access the Website and to provide the Services or as specifically set forth in this Policy.

2. Changes to this Policy. InvestNext reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material InvestNext may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the Website after such changes have been made constitutes acceptance of those changes. You will be directed to the applicable Policy upon your creation of an account which allows you access to any restricted portion of the Website.

Collection of Information

1. Information that You Provide. InvestNext collects any information that you voluntarily provide, including when you submit information requesting a demonstration, joining the e-mail list, applying for a job or when you use the Services available through the Website. Information that you may provide includes your email address, name, phone number, location, details of your education, online social accounts and professional resume or CV. InvestNext may also collect information that you provide by electronic mail, telephone or other means.

2. Automatically Collected Information. InvestNext may automatically collect certain technical information from your computer or mobile device when you use the Website, such as your Internet Protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website. This information allows InvestNext to recognize you and personalize your experience if you return to the Website using the same computer or mobile device, and to improve the Website and the Services.

3. Information about Legal and Other Materials. In addition, InvestNext may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials and approval or execution of contracts, consents or other statements or agreements by means of the Website, including the Website’s Terms of Use and this Policy.

4. Cookies. InvestNext may collect this information using “cookies,” which are small text files that the Website saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the Website. InvestNext may also collect information from the Website and the email list using “web beacons,” which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help InvestNext compile information about your interactions with electronic mail sent to you in connection with the Services. For further information, see the Cookie Policy below.

5. Cross-Site Tracking. InvestNext does not utilize technical measures in the Website to track your activities across different web sites or online services, whether you configure your browser’s Do Not Track feature or otherwise. The Website does utilize third-party application programming interfaces controlled by third parties, such as marketing tracking services, that may attempt to track your activity across other sites that utilize those interfaces.

Use and Disclosure of Information

InvestNext may collect, use, share, and otherwise process your personal information for a number of purposes, including, but not limited to:

1. Accessing the Website and Providing the Services. InvestNext uses your Personal Information to provide you with the Services, or products, services or information related to the Website and to customize your experience when using the Website, such as by providing interactive or personalized elements on the Website and providing you with content based on your interests. The legal basis for such use are the Website’s Terms of Use and this Policy.

2. Analysis. InvestNext uses your Personal Information for improving the quality of the Website and/or the Services, including by (i) combining or aggregating any of the information collected through the Website or elsewhere for generating and analyzing statistics about your use of the Website and user demographics and traffic patterns and (ii) using anonymized data that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Services and developing new Service offerings. The legal basis for such use are the Website’s Terms of Use and this Policy and InvestNext’s legitimate interest in improving the Website and Services.

3. Marketing. If you submit your information to InvestNext, InvestNext may provide you with information about the Website, Services or required notices. In addition, InvestNext may use collected information for delivering marketing communications that may be of interest to you. InvestNext does not sell or share your Personal Information with other companies so that they can market to you. You have the right to ask InvestNext not to process your Personal Information for marketing purposes. InvestNext will usually inform you (before collecting your information) if it intends to use your information for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms InvestNext uses to collect your information. You can also exercise the right at any time by contacting InvestNext at privacy@investnext.com, or clicking “unsubscribe” at the bottom of the InvestNext marketing communications.

4. Security. InvestNext may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue InvestNext’s legitimate interests in ensuring the security of the Website and Services, including detecting, preventing and responding to fraud, intellectual property infringement, violations of the Website’s Terms of Use, violations of law or other misuse of the Website; and when InvestNext believes in good faith that disclosure is necessary (A) to protect InvestNext’s rights or other users of the Website, the integrity of the Website, or your safety or the safety of others, or (B) to detect, prevent or respond to fraud, intellectual property infringement, violations of the Website’s Terms of Use, violations of law or other misuse of the Website.

5. Service Providers. InvestNext engages third-party service providers (such as hosting providers and analytics and security providers) to assist in operating and marketing the Services. InvestNext’s engagement of third-party service providers is often necessary for InvestNext to provide the Services to you, particularly where such third-party service providers ensure that the Website and Services are operating and secure. In other cases, InvestNext has a legitimate interest in third-party service providers that can help improve the Website and the Service.

6. Other Disclosure. InvestNext may disclose Personal Information about you to others: (a) if InvestNext has your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the InvestNext terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. InvestNext may also transfer your Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, acquisition or sale, joint venture, assignment, transfer or other disposition of all or any portion of InvestNext’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that InvestNext transfer Personal Information to will not be permitted to process your Personal Information other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.

Storage

1. Jurisdiction. Information collected through the Website will be stored in, processed in and subject to the laws of the United States, which may not provide the same level of protection for your information as your home country, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Website, you consent to such transfer to, storage in and processing within the United States.

2. Security. InvestNext is committed to protecting your information from unauthorized access, use or disclosure. The Website and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the Website. However, no information or communication Website can be 100% secure, so InvestNext cannot guarantee the absolute security of your information. In addition, InvestNext is not responsible for the security of information that you transmit to the Website over networks that InvestNext does not control, including the Internet and wireless networks.

3. Retention. InvestNext will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. If you wish to access or correct any information InvestNext holds about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). InvestNext also collects and retains information through the Website in an anonymized form, i.e. tracking the pages you visit and how long was spent on each page. If you are a customer of InvestNext or an end user accessing the Services through an investor portal, your data may be subject to a different privacy policy and your data will be retained in accordance with terms applicable to such access to the services.

Cookie Policy

This section provides InvestNext’s cookie policy and describes how InvestNext uses Cookies and similar technologies. For more information on InvestNext’s general data privacy practices, please see the full Policy.

1. Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. InvestNext uses cookies, web beacons and similar technologies (“Cookies”) to enhance your user experience, understand your usage of the Website and Services and to perform analytics. Cookies may also be set by other websites or services that run content on the page you are visiting. The provision of your data via Cookies is voluntary except for those Cookies that InvestNext places on your device because it is necessary for the performance of the Website or Services. InvestNext uses “session cookies” and “persistent cookies.” Session Cookies are temporary Cookies that remain on your device until you leave the Website or Services. A persistent Cookie may remain on your device for much longer until you manually delete it.

2. Use. Cookies can contain the following information about you and your use of the Website: browser type, search preferences, data relating to which pages of the Website that you have visited and the date and time of your use. InvestNext uses Cookies for the following purposes:

a. To enable and support security features, prevent fraud, and protect your data from unauthorized access.

b. To enable features and help us provide you with personalized content.

c. To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.

3. Third-Party Cookies. InvestNext uses the following third-party Cookies on the Website:

a. Google Analytics. Google Analytics tracks unique visitors to the Website, and provides analytics reports showing website usage and referral sources. It also helps determine whether visitors have arrived at the Website via Google marketing campaigns. See https://policies.google.com/privacy for details.

b. Facebook. Facebook’s tracking determines whether visitors have arrived at the Website via Facebook marketing campaigns. See https://www.facebook.com/about/privacy for details.

c. HubSpot. Salesloft determines whether visitors have arrived at the Website via our email correspondence with them. See https://legal.hubspot.com/privacy-policy for details.

d. Suarespace. Squarespace tracks and reports on which parts of the Website are most engaging for visitors. See https://www.squarespace.com/privacy for details.

e. Bing. Bing’s tracking determines whether visitors have arrived at the Website via Bing marketing campaigns. See https://privacy.microsoft.com/en-us/privacystatement for details.

f. Wistia. Wistia hosts the video content embedded in the Website. It tracks how many visitors play embedded videos, and how much of each video they play. See https://wisti1.com/privacy for details.

g. MailChimp. If you subscribe to our newsletter, InvestNext uses MailChimp for correspondence with you. MailChimp may utilize web beacons or other cookies in their internal operations. See https://mailchimp.com/legal/privacy/ for more details.

h. Capterra. Capterra’s tracking determines whether visitors have arrived at the Website via Capterra marketing campaigns. See https://www.capterra.com/legal/privacy-policy for details.

4. Opting Out. You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by InvestNext.

GDPR

1. From May 25th, 2018, if you are a resident of the European Union, InvestNext will process your Personal Information in compliance with the EU General Data Protection Regulation (“GDPR”). For information submitted using the Website, InvestNext, LLC is the data controller, as defined under GDPR. In accordance with GDPR, as a data subject you will be accorded with any applicable rights, which may include the following:

a. right of confirmation;

b. right of access;

c. right to rectification;

d. right to erasure;

e. right of restriction of processing;

f. right to data portability;

g. right to object;

h. right to withdraw data protection consent; and

i. the right to lodge a complaint with a supervisory authority.

Third-Party Websites

The Website and communications from InvestNext may contain links to websites operated by third parties. You acknowledge and agree that InvestNext is not responsible for the collection and use of your information by such websites that are not under InvestNext’s control. InvestNext encourages you to review the privacy policies of each website you visit.

Children’s Information

The Website is not directed to, nor does InvestNext knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact InvestNext immediately using the contact information provided below.

Other Agreements

You may from time to time enter into binding legal agreements relating to certain Services available through the Website, which may have terms that are different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.

Contact Information

If you have any questions about this Policy or the collection or use of information about you, please write to InvestNext at privacy@investnext.com or 1420 Washington Blvd, Detroit, MI 48226