Last Modified: July 9, 2020
This website, www.gosteward.com (the “Site”) is a website owned by Steward Technologies LLC, a Limited Liability Company with its mailing address at 9450 SW Gemini Dr #41153, Beaverton, OR 97008, USA (“Steward Technologies,” “us,” “our” or “we”).
Neither Steward Lending LLC nor Steward Technologies is a registered broker-dealer or an investment adviser. We do not provide financial advice or investment recommendations; any information or representations made on our Site do not constitute and should not be construed as investment advice or recommendations.
With respect to Syndicated Loans and Loan Participations, all information provided with respect to a project on the Site is the responsibility of the individual Borrower responsible for the Project.
With respect to any securities offerings listed here, all securities are being offered by, and all information included on this Site is the responsibility of, the applicable issuer of such securities. Steward Technologies has not taken any steps to verify the adequacy, accuracy or completeness of any information. Neither Steward Technologies nor any of its officers, directors, agents or employees makes any warranty, express or implied, of any kind whatsoever regarding the adequacy, accuracy or completeness of any information on this site or the use of information on this site.
Personal Data. Personal data, sometimes called “personally identifiable information” in the United States (“Personal Data”) is information that can be used to identify you as an individual, such as a name, an identification number, location data, or an online identifier. It also includes factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity which can assist someone in eventually identifying who you are. Steward Technologies collects Personal Data from you when you use our Site in various ways such as signing up for an account, completing forms or applications on our Site, sending us an email through our Site, or engaging in a transaction through our Site. Steward Technologies may also collect information which may be contained on server logs, such as your Internet protocol (“IP”) address.
The types of Personal Data that we collect through our Site may include, but are not limited to, your: (1) personal name; (2) email address; (3) physical address; (4) phone number; (5) date of birth; (6) Social Security Number; (7) information from an identity document such as a passport or driver’s license; (8) business name; (9) business address; (10) job title; (11) articles of incorporation; (12) credit card information; (13) bank account information; and (14) any other Personal Data you may voluntarily provide.
Additional data that we collect and store in our log files may include, for example, frequency of visits to our Site, time spent viewing pages on our Site, date(s) and time(s) of visits to our Site, clickstream data, cookies existing on your computer, operating system, browser type, device type used to visit our Site (desktop or mobile), and sites visited before arriving at our Site. We collect this information through automated tracking technologies, some of which are discussed below, and we may combine this automatically collected information with other information we collect about you. We do this to improve services we offer you and to improve our Site.
We obtain Personal Data from third party sources. Types and uses of such third party sources may include: (1) services used to verify identity and backgrounds; (2) services used for anti-money laundering screening; or (3) payment facilitation services.
We collect the above information about you when you voluntarily provide it through our Site. For example, we collect information you provide to us when you complete forms on our Site such as when you create your user account or submit inquiries, feedback, or comments to us by email. We also collect other information or content from you when you upload it voluntarily to our Site.
We, our Affiliated Companies, and our service providers may also collect information about you using various automated technologies on our Site such as those described below:
The above technologies are used in analyzing trends, administering our Site, tracking users’ movements around our Site and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by third-party companies on an individual as well as aggregated basis. This information helps us with improving our Site.
Steward Technologies will use Personal Data and other Information: (1) to market our Site or our affiliates’ websites, products, and services to you and other users of our Site; (2) analyze data to send more targeted messages to users of our Site; (3) to conduct research and analyze data to improve our products, services, and Site; (4) to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our Site and other services; (5) to fulfill product and service requests; (6) to deliver email messages like special offers, updates, newsletters, customer service, and service announcements; (7) to comply with and meet any regulatory requirements for the offer or sale of securities required by law; (8) to protect our Site or its users; (9) to engage in any other lawful activities we believe are consistent with the foregoing; and (10) when required by law (for example, to comply with a subpoena or similar legal process), when we deem it necessary to protect against legal liability, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
We may provide or obtain any of the above services through third parties, which may necessitate sharing Personal Data with them. With regard to use of your information for marketing, none of the information is shared beyond Steward Technologies’ affiliates.
We may make certain Personal Data available on our Site and visible to other users of or visitors to our Site. For instance, by default your first name and last name initial will be shown if you invest in a securities offering on our Site. Our Site may have a feature that enables you to opt-in to display your whole name along with a short bio, your location, Site investment history, and social media handles. Prospective borrowers seeking financing via our Syndicated Loan offerings will have to provide more extensive Personal Data on their offering page, such as the names of their officers and directors, their biographies and background, that will be viewable by other users of our Site.
Steward Technologies may share your personal information with affiliated companies, for the lawful purposes set forth in this Policy, as necessary to provide products and services to you .
Steward Technologies employs or contracts with third-party companies or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification, accreditation/financial/credit verification, electronic document signing, payment storing and facilitation, sending e-mail, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. Steward Technologies may share with these third parties, and these third parties may have access to, your information, including Personal Data needed to perform their functions or services for users of our Site. However, these third parties may not use your information for other purposes. To the extent that your Non-Personal Data or Personal Data is provided to such third parties, the information will be collected and used by the third parties only to perform their prescribed functions or services.
Transfers Relating to Our Own Corporate Transactions. We may have to transfer your information to a buyer or other successor to our business in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Steward Technologies’ assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Data Information held by us about our Site users is among the assets transferred.
Steward Technologies believes that it complies with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. If you have a question or complaint related to Steward Technologies’ participation in the EU-US or Swiss-US Privacy Shield, we encourage you to contact us at email@example.com. For any complaints related to the Privacy Shield frameworks that Steward Technologies cannot resolve directly, we have chosen to cooperate with the relevant Data Protection Authority, or a panel established by the European data protection authorities for resolving disputes. Please contact us if you’d like us to provide you with contact information for your Data Protection Authority. As further explained in the Privacy Shield Principles, which you can find at https://www.privacyshield.org, binding arbitration is available to address residual complaints not resolved by other means.
We or our affiliates may at times send you e-mail communications with general marketing information, even though none of your Personal Data is shared for marketing purposes beyond Steward Technologies’ affiliates. If you prefer not to receive such marketing or promotional e-mails, you may unsubscribe via your account dashboard or by emailing us at: firstname.lastname@example.org or you may choose to stop receiving our newsletter or marketing emails by following the “unsubscribe” instructions included in these emails. However, you cannot opt out of receiving certain types of email communications such as emails regarding specific transactions you have participated in on our Site, legal notices we may be required to give, or emails responding to specific inquiries from you.
Please also note that at times we may need to send you e-mail communications which are transactional in nature and which you will not be able to opt-out of, such as service or termination announcements or payment confirmations.
You have certain rights concerning the data we process about you. This includes, among others, the right to access your Personal Data, to object to the processing of your personal data, and to rectify, erase, and export your Personal Data.
For Personal Data that we process based on your consent, you have the right to withdraw that consent. You may withdraw your consent by emailing email@example.com with “CONSENT WITHDRAWN” in the subject line.
If we process your personal data based on the legitimate interests of our organization or of third parties, you have the right to raise an objection to such processing by contacting us at firstname.lastname@example.org.
You can choose to delete your account and any Personal Data associated with that account. However, we will have the right to retain and use your Personal Data as necessary to comply with our legal obligations, provide our services, resolve disputes, and enforce our legal agreements. For example, we may need to retain archival copies of your information for legal or compliance purposes even after you have requested its deletion.
We generally retain your Personal Data only for as long as is necessary to accomplish the purposes for which we processed the data, including delivering to you the services for which you accessed our website.
With regard to certain types of Personal Data, you have provided consent for a retention period of longer duration than the period we would be required to preserve it in order to complete the processing for the purposes you intended. In that case, we will retain the data in accordance with your consent.
If an item of Personal Data is of a particularly sensitive type, we will shorten the retention time period that we would otherwise normally observe.
In some cases, you have provided Personal Data with the manifested intention that it be retained until you yourself initiate its removal. Nevertheless, in this and other cases, we may be forced to delete the data sooner than you wish if, for example, you exceed the limit on the quantity of data that we can store in your account.
Our website may provide automated controls which give you the freedom to delete Personal Data any time you wish. In the absence of such controls, we are likely to prescribe a shortened data retention period.
If we adopt a data retention program or schedule prescribing various retention periods for different types of Personal Data, we will post it on our website.
There are certain exceptions to our policy of retaining your Personal Data for only as long as is necessary to accomplish the purposes for which you wanted to have the data processed in the first place. We will retain your Personal Data for as long as is necessary to comply with our legal obligations, including contractual obligations, to serve our legitimate interests, and to pursue our rights and remedies and defend ourselves in litigation and other proceedings with individuals, business entities and governmental authorities. We may be required by law to preserve information, including Personal Data, that is relevant to such proceedings for a prescribed period of time. We will take appropriate technical and institutional measures to safeguard your rights and freedoms as required by the GDPR.
The periods for which we are required to retain data can vary depending upon the data type, the country or other jurisdiction in question, the nature of our interactions with you, or your use of various features of our website and the services we provide through our website. We may be subject to data retention laws or mandatory data removal laws based on content, government orders to preserve data in connection with an investigation, or data required to be retained in adversarial proceedings pursuant to a court order, administrative order, or applicable rules of court or arbitration procedure.
We use reasonable efforts to secure access to Personal Data in our possession but will not be liable for any failure to safeguard such information, whether inadvertent or otherwise. Information you provide to us is encrypted and stored securely on private cloud servers through third-party service providers that we use. We also take commercially reasonable efforts to store as little sensitive information as possible.
We are required to notify you without undue delay in the event of a data breach on our part causing high risk to data subjects. The notification must include at least: the name and contact details of the DPO (or other relevant point of contact); the likely consequences of the data breach; and any measures taken by us to remedy or mitigate the breach. However, we may be exempt from this requirement if: the risk of harm is remote because the affected data are protected (e.g., through strong encryption); we have taken measures to protect against the harm (e.g., suspending affected accounts); or the notification requires disproportionate effort (in which case we must issue a public notice of the breach).
Though we and our service providers, who have informed us that they also use reasonable efforts to secure Personal Data, take commercially reasonable efforts to keep secure any Personal Data, there is no guarantee that any communication over the public Internet is 100% secure at all times. Therefore, neither we nor our service providers shall be held liable for the failure to safeguard Personal Data, whether inadvertent or otherwise, except where you, as a data subject, prove that you have suffered material or non-material damage as a result of our infringement of the GDPR, in which event you shall have the right to receive compensation from us, in our capacity as data controller or processor, for the damage suffered.
It is also important for you to protect against unauthorized access to your password and to your computer. Be sure to log off any computer or device you use to access your account on our Site after you have finished.
The Steward Technologies Site is not intended for use by children. No one under eighteen (18) years of age is allowed to use our Site, provide any Personal Data or receive our email distributions. We do not knowingly solicit or collect Personal Data from children under the age of thirteen (13) or anyone under eighteen years of age. If you believe that anyone under these ages has disclosed Personal Data to Steward Technologies, please report this to us immediately by emailing us at email@example.com.
For users in the EU, you have the right to bring a complaint with the independent public authority responsible for data protection in the EU member country of your habitual residence, place of work or place where you think our processing of your Personal Data infringed the GDPR. Before you do so, we ask that you give us the opportunity to resolve your complaint to your satisfaction within thirty (30) days of your contacting us about it at firstname.lastname@example.org.