Vicinity values your privacy. We appreciate the importance of maintaining the confidentiality of information that you have shared with us and take seriously the responsibility of safeguarding your privacy while we assist you in achieving your financial objectives.
In this Privacy Notice, the terms “we,” “our” and “us” refer to Vicinity LLC (“Vicinity”), a crowdfunding portal that has applied to be registered with FINRA (the Financial Industry Regulatory Authority), our principals and our employees or as independent contractors. Vicinity LLC is a South Carolina limited liability company.
The terms “you” and “your” in this Privacy Notice refer broadly to all of our individual clients (including prospective and former individual clients).
This Privacy Notice is being delivered to you now pursuant the federal law that requires crowdfunding platforms to inform their clients of the crowdfunding platform’s policies regarding the privacy of client information. The purpose of this Privacy Notice is to describe the types of non-public information we collect about you, explain to you what we will do with this information, and explain the ways that we protect your privacy.
If we change our information practices, we will provide you notice of any material changes. If you become an inactive client, we will continue to adhere to the privacy policies and practices as described in this notice. This Privacy Notice supersedes all previous notices or statements with respect to subject matters described in this Privacy Notice.
If you are comfortable with our handling of information we collect, you do not need to take any action at this time. Please read this Privacy Notice and keep it for your records.
Your use of the Service is also subject to the Terms of Service. All capitalized terms have the same meaning as defined in the Terms of Service unless otherwise stated herein.
Personal Identifiable Information (PII)
PII is information that identifies you or can be used to identify, contact, or locate you.
Vicinity may ask you for PII, which may be identifiable to you when you register for our Services, access various content or features, or directly contact the site. You are responsible for ensuring the accuracy of all PII you submit to Vicinity.
We may also have access to your PII when you log into our website through certain third party social networking services, including Facebook, LinkedIn, Twitter and Internet Chat (“Third Party Services”). We encourage you to carefully review the privacy policies of any Third Party Services from which you access our website.
In addition, if you choose to purchase or subscribe to a feature or Services of Vicinity that requires a Fee, you will be required to provide us with your billing information, including, without limitation: bank account numbers, credit card numbers, debit card numbers, account details, ACH information, and similar data (collectively, “Billing Information”).
Types of Non-Public Personal Information that We Collect
To help the United States government fight the funding of terrorism and money-laundering activities, Federal Law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.
Vicinity requires users who wish to use the Site or Services to register by completing the appropriate Vicinity registration process. During registration, you may be required to provide contact information including, but not limited to: your full name, e-mail address, username and password, and geographic location.
When you indicate an interest in investing through Vicinity’s crowdfunding platform, we will ask for your name, address, date of birth, social security number or employer identification and other information that will allow us to identify you. We will also ask to see your driver’s license, passport or other identifying documents that contain your photograph.
In the conduct of our business, Vicinity also collects PII from you when you sign up for an account, send us an email through the Site, sign up for a service through the Site, or make an investment through the Site. Personally Identifiable Information refers to non-public information that personally relates to or identifies you (such as your name, password, age, date of birth, gender, email address, postal mailing address, home/mobile telephone number and/or taxpayer identification number, Internet protocol (“IP”) address, investment objectives, investment experience, assets, income, and other similar information, or other information you provide or upload to the Site such as photographs, answers to questionnaires or surveys, or responses filled in on blank forms by you made available on the Site). We request that you provide us with personal information, including, but not limited to, your personal or company social media profile, demographic information, financial information about issuers (i.e. valuations, share prices, fundraising goals), financial information about individuals (i.e. net worth) and other information requested from time to time. We may also collect and store information locally on your computer or device using mechanisms such as browser web storage or application data caches.
How We Use Your Personal Information
We respect your privacy. We only collect PII through optional, voluntary submissions, such as email, survey information, and online registration forms. The types and amount of personal information collected from these activities will vary, but in no event will we collect PII that is not voluntarily given by you when using Vicinity’s Service. You consent to Vicinity using your PII to facilitate requests, to contact you if a problem arises, email you information about our services, or for other uses consistent with this Policy and your requests.
We will use any information you provide consistently with the terms of this Privacy Notice. We use your non-public personal information only for legitimate business purposes that are consistent with crowdfunding platform practices and are in compliance with applicable laws and regulations including:
To select and close on transactions in which you have chosen to invest. For example, we use information that you provide to us regarding your interest in a particular offering in order to gauge whether sufficient interest exists to fund a particular investment opportunity.
To comply with applicable laws and regulations. For example, we use information gathered in your investor questionnaire to insure that we are offering our investment opportunities consistent with the requirements of federal and state securities laws and regulations and the rules and requirements of the Financial Industry Regulatory Authority.
To help us inform you of investment opportunities. For example, we use information about your prior investments to assist us in determining subsequent offerings in which you may be interested.
Non-Personal Information (Non-PII)
Protecting Your Information
We restrict access to non-public personal information about you to those of our employees and service providers who need to know this information to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information.
Our Use of Your Information
Our primary purpose in collecting information is to provide you with a safe and customized experience. You agree that we may use your information to: provide the Services and customer support you request; troubleshoot problems and prevent potentially prohibited or illegal activities; customize, measure and improve our Site, our Services, content and advertising; tell you about and administer our Site, or Services, targeted marketing, service updates, contests, sweepstakes, rewards, and promotional offers based on your communication preferences; monitor and enforce our Terms of Service; communicate with Users about products and/or services you may be interested in; verify your eligibility to use the Site.
Our Disclosure of Your Information
Vicinity is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you. We may disclose Personal Information, Billing Information and Non-Personal Information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.
We may also use and/or share your PII, Billing Information and Non-PII with, and you authorize us to use and/or share this information with:
Service providers under contract who help with our business operations.
We may combine your information with information we collect from other companies and use it to improve and personalize our services, content and advertising.
We may share some or all of your information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
As we develop our businesses, we might sell or buy other businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the PII and Non-PII may be part of the transferred assets.
Information We Disclose to Third Parties
In order to conduct our business on your behalf, we are sometimes required to disclose your personal information to companies or entities that are not affiliated with us. On those occasions when it is necessary for us to share your personal information with non-affiliated companies, we do not disclose this information to these companies except as permitted by law.
While we never sell your personal information, it is often necessary for us to provide your personal information to third parties to provide you with better service or to third parties that we have engaged to assist us in closing a particular transaction. It is also sometimes necessary to share information related to a specific transaction with third parties who are only involved with that transaction.
We will not share your non-public personal information with third parties to be used for promotion or marketing purposes.
Use of IP Addresses
As with any Internet-based service, queries to our service transmit an Internet Protocol (IP) address, as this is what allows delivery of the information you requested back to you. We also use IP addresses for security purposes and to determine the approximate geographic location (the country or metropolitan region) of the query. We use the approximate geographic location to create aggregate statistics, such as use or non-use of the Content by country or region, which we may share with the owner of the Content. We do not use IP addresses to identify an individual user by name, address or exact location. It is possible that we might be legally required to make a disclosure, for example, in response to court orders or in governmental investigations.
Cookies, Login Information and Opt Out
User Communication and Opt-Out
We may at times send you e-mail communications with information, marketing or promotional materials. If you prefer not to receive such emails from us, you may unsubscribe completely by selecting “unsubscribe” at the bottom of the emails you receive. Please note that opt-out requests may take up to five business days to process.
You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
To manage our advertising on other sites, we engage third-party advertising partners. These third-party partners may use technologies such as cookies to gather information about your activities on the Site and other sites in order to provide you advertising based upon your browsing activities and interests. Certain of our third-party advertising partners participate in self-regulatory organizations, and those organizations operate websites that give you the ability to opt-out of receiving targeted ads from those partners.
To be clear, whether you are opting out by adjusting your browser/device settings or by using a website established by a self-regulatory group, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.
Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third-party who has previously been provided with your information in accordance with this policy.
When you send an email or other communication to Vicinity, we may retain those communications and related e-mail addresses in order to process your inquiries, respond to your requests and improve our services. In addition, Vicinity may use your username and email address to provide you with email newsletters, announcements, Vicinity news about products and/or services and information about your user account. If you do not wish to receive these kinds of communications, you may “opt out” either by: (a) unchecking the email newsletters and announcements during registration; or (b) by doing the same within your user profile.
Social Media Features
You can log in to our site using sign-in services such as LinkedIn. 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.
We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Nevertheless, no transmission over the Internet and no data storage method can be guaranteed to be safe 100% of the time. Vicinity cannot ensure or warrant the security of any information you transmit to Vicinity or guarantee that your end user data stored on the Site or the Services may not be accessed, disclosed, altered, or destroyed by breach of any of our industry standard physical, technical, or managerial safeguards. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
The Site is hosted on servers in the United States. Accordingly, if you are located outside of the United States, any information you provide to us will be transferred to the United States. By providing us with any information, you consent to its transfer and storage in the United States.
Vicinity may disclose any information we collect, including both PII and Non-PII, if required to do so by law or under a good faith belief that such action is necessary to conform to the law or comply with legal process or to protect and defend Vicinity’s rights, property, and customers, whether or not required to do so by law. Vicinity reserves the right to contact appropriate authorities and disclose such information to them at its discretion when it appears that individuals using Vicinity’s products or services are engaged in activities that are illegal or violate our Terms of Service.
Vicinity maintains a variety of physical, electronic and procedural safeguards to guard your information and to deliver the services and features of the Service. While Vicinity cannot guarantee that loss, misuse or alteration of your data will not occur, we work hard to prevent such occurrences. We will also retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Children – Children’s Online Privacy Protection Act
This Website is not intended for use by children. No one under eighteen years of age is permitted to use the Website, to make investments through Vicinity, to provide any personal information or to receive our email distributions.
VicinityCapital.com is maintained in the United States of America. By accessing VicinityCapital.com , you consent to and authorize the export of Personally Identifiable Information to the United States of America and its storage and use as specified in this Privacy Notice. This Privacy Notice shall be governed by, construed and entered in accordance with the laws of the State of South Carolina applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Notice shall be brought and heard either in the South Carolina State Courts located in the county of Greenville, South Carolina, or the federal district court for District of South Carolina. You consent to the in personam jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.
Deletion of and Access to your Personal Information
In the event you desire to be informed of or access all of the personally identifiable information we hold about you, and you may do so by visiting your user account when logged-in to the Service, or by e-mailing us at the address the forth below. You also have the right to delete such personal information and your account at any time. Please note, however, that once you delete such information, it may not be recoverable.
Business Continuity Plan
In accordance with federal requirements, Vicinity maintains a Business Continuity Plan that describes what steps will be taken to ensure the continuity of our business operation in the event of an unanticipated disaster. The plan has been designed with procedures to ensure that client documentation will be accessible and that contact between Vicinity and its clients will be sustained.
If you would like a copy, please contact our office.
How to Contact Us