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Privacy Policy

Your Privacy

The website MicroVentures.com and the services available on it (collectively, we'll refer to these as the MicroVenture services) are provided to you by MicroVenture Marketplace Inc. As we provide you (or the organization for which you are acting) with the MicroVenture services, we collect some personal information. This Privacy Policy tells you how MicroVenture uses and works to protect your information.

By using MicroVenture, you agree to the terms and conditions of the User Agreement, including this Privacy Policy, and you consent to our privacy practices. This includes the use and disclosure of any personal information you have shared with us and its transfer to and storage on our servers in the United States, as described below.

Collection

When you register for the MicroVenture services and apply for an account, we may collect information about you, including:

  • Information that you provide to us to set up a user account for you and identify you on the site, including user name, password, and secret questions and answers.
  • Contact information, including first and last name, phone number, fax number, email address and mailing address.
  • Payment information, including email address, bank account and routing number.
  • Profile information, including your investment preferences and other information you may provide us that allows us to customize your MicroVenture experience.
  • Other information we are required by law to collect from you, or from consumer reporting agencies, to process securities-related transactions, to assess the suitability of various investments, and to comply with tax laws and anti-money laundering laws. This includes Social Security number, date of birth, gender, country of citizenship, liquid assets, net worth, education, occupation, employment status, employer contact information, annual income, investment objectives and suitability profile.

We may obtain information about you when you interact with MicroVenture, for example, your transaction history, information about your contacts with Customer Service, and your responses to promotions or special offers.

We may collect some information automatically from your computer while you browse our website, such as where you go on the site and what you do there. We collect your Internet Protocol (IP) address, computer and connection information, browser type and version, operating system, Internet Service Provider (ISP), time stamps, banner ads you click, the URLs you come from and go to next, and a cookie number.

We may also obtain information about you through other sources such as credit agencies, affiliates and business partners.

Use

We use the information we collect to:

  • Operate the MicroVenture site.
  • Verify your identity and contact information.
  • Provide you with information and services you request.
  • Set up your trading account, issue an account number and a secure password, maintain your portfolio and trading activity, and contact you with account information.
  • Customize your experience on the MicroVenture site.
  • Communicate with you about your transactions, service updates and other administrative issues.
  • Send you targeted marketing and promotional offers, based on your communications preferences.
  • Measure and improve our site and services.
  • Resolve disputes, address complaints and troubleshoot technical problems.
  • Analyze site and user behavior and prepare aggregated reports.
  • Comply with applicable laws and regulations.
Sharing and Disclosure

The cornerstone of this Privacy Policy is our commitment to keep your personal information confidential. MicroVenture Marketplace does not sell, license, lease or otherwise disclose your personal information to any third party for purposes of marketing by the third party or for any reason, except as described below. To provide our products and services, we may disclose your information to the following parties:

Issuers. We may share your information with our participating issuers. They will use the information only as necessary to complete your transactions and to include collect the information needed to register you as a shareholder of the issuer and issue the shares that you have purchased.

MicroVentures.com Affiliates. We may share information with present or future affiliates, including our subsidiaries, joint ventures or other companies under common control, where it may be used to provide joint services or for such purposes as internal statistics, strategic decision-making, customer reviews, identifying customer trends, customer verification, fraud prevention and security. You may limit our affiliates from marketing their products or services to you based on personal information that we collect about you and share with them. This information may include your name, email address, mailing address, age, employment status, general account and demographic information and account history with us. Your choice to limit marketing offers from our affiliates will apply until you tell us to change your choice. You can opt back in at any time. To limit affiliate marketing offers, contact us by e-mail at , change your account preferences in My Account or contact us at Customer Service.

Service Providers. We may share information with service providers under contract who help with our business operations and internal functions, for example, verifying our users, processing accounts, order fulfillment, client service, client satisfaction surveys or other data collection activities relevant to our business, maintaining the MicroVenture site, and providing related services, such as electronic funds transfers and wires. Our service providers are required to protect personal information in a manner similar to the way we protect personal information and to use it only for the services they provide to us.

Legal and Other Disclosures. We may disclose information when permitted by law or under the good-faith belief that such disclosure is necessary under applicable law; to comply with legal process served on MicroVenture; to protect the property or interests of MicroVenture, its agents and employees; or to protect personal safety or the public.

Assets. As our business evolves, MicroVenture may sell, transfer or otherwise share some or all of its assets in connection with a merger, reorganization or sale of assets, or in the event of bankruptcy. In such an event, personal information may be one of the assets transferred.

If we propose to share information in a manner not covered in this Privacy Policy, we will notify you of this change by posting an addendum on our site, a notice in the "Announcements" or "What's New" section of the site, and if appropriate, provide you an opportunity to opt out of such use.

Email Communications

Choice/Opt-Out. Because we do not share your personal information with non-affiliated third parties for marketing purposes, there is no need for you to opt out of such uses. At any time, you have the ability to opt out of receiving marketing communications from MicroVenture, but you may not opt out of administrative emails (for example, electronic delivery of financial information, or emails about your transactions or our policy changes) while you are a registered MicroVenture user. In such cases, you can opt out by changing your email preferences in My Account or by using the link provided at the bottom of each marketing email.

Email Tools. If you send emails to a recipient through our site, they will receive your email address and any personal message you include. We use the email addresses you provide to send your requested communication and for no other purpose. We may be required by law to retain these emails; they are not private communications. You may not use our email tools to send spam or content that violates the User Agreement.

Anti-Spam Policy. MicroVenture does not tolerate spam. We do not send emails to anyone without permission, and we do not sell or rent email addresses to any unauthorized third party. This does not mean that we can prevent spam from happening on the Internet. If you believe that you have received an unsolicited email from us, please contact Customer Service and we will investigate.

Cookies and Web Beacons

MicroVenture, our service providers, and other members of our corporate family who provide us with joint services, will sometimes place anonymous cookies or web beacons on your computer when you visit the site. We use these cookies and web beacons to recognize returning users, provide relevant content, measure traffic and activity on the site, monitor and improve our services and protect against fraud. You can block cookies by changing the settings on your browser (consult your browser help menu to find out how), but doing so may prevent us from delivering certain services to you. Your browser must be set to accept cookies in order to access MicroVenture as a registered user.

Accessing, Reviewing and Changing Your Personal Information

We urge you to review your information regularly to ensure that it is correct and complete. As a registered user, you can review and change your personal information by accessing My Account. You may not be able to change some account information online. If you are unable to make your desired change in My Account, please contact Customer Service for assistance. Although we will require you to revalidate your personal information periodically, you should promptly update your personal information if it changes or becomes inaccurate.

You can request that we close your MicroVenture account by e-mailing Customer Service at . After we close your account, we may retain some information to comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our User Agreement and take actions otherwise permitted by law. If your account or membership is terminated or suspended, we may retain some information to prevent re-registration.

Security

We view protection of your privacy as a very important principle. We store and process your information on computers located in the United States that are protected by physical as well as technological security devices. We have implemented physical, electronic and procedural safeguards that are designed to protect the security of your information in compliance with applicable U.S. federal and state regulations. These include advanced firewall and password protection for our databases, physical access controls to our buildings and files, and restricted access to your personal information to employees that need to know that information to operate, develop or improve our services.

We have invested in leading-edge security software, systems and procedures to offer you a safe and secure investing platform and protect your personal, financial and investment information. While no security system is absolutely impenetrable, we will continually monitor the effectiveness of our security system and refine and upgrade our security technology as new tools become available.

Links to Other Sites

The MicroVenture site may contain links to other websites. We are not responsible for the privacy practices or the content of these sites. If you have concerns about how another website collects and uses information about you, make sure to read that site's own privacy policy.

General

We may change this policy from time to time, and we will post the amended terms on the MicroVenture site and notify you by email of major changes. Amended terms will take effect immediately for new users, and 30 days after they are posted for existing users. You should review this Privacy Policy periodically to remain informed of any changes. You agree to accept posting of a revised Privacy Policy electronically on this site as actual notice to you.

We are strongly committed to our relationship with you and want to be sure you understand the steps we have taken to protect your personal information. If you have any questions, complaints or comments, please e-mail us at or contact us at Customer Service.


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