Privacy Policy

Last Modified: October 15, 2019

About This Website; Company Information

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”).

Steward Technologies is not 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.

All securities listed here 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.

As explained below, we collect information from you (“you”, “your”, or “user”) in various ways when you use or interact with our Site. Please also see our Terms of Use posted on our Site for the terms and conditions of visiting and using our Site.

Your Consent to This Privacy Policy; Withdrawal of Consent

In order to use our Site, you must consent to our collection and use of information as explained in this Privacy Policy, and you must agree to be bound by our Terms of Use. 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 You may withdraw your consent by emailing support@gosteward.com with “CONSENT WITHDRAWN” in the subject line. If we post an updated version of this Privacy Policy and you continue to use our Site thereafter, your continued use of our Site will also mean that you consent to the updated Privacy Policy. If you do not agree to this Privacy Policy, you must not use our Site. Please note that if you choose to invest in any securities offering posted on our Site, you may be required to accept the terms of a separate agreement, including, but not limited to, a Subscription Agreement or Loan Participation Agreement.

Purpose of This Privacy Policy

Steward Technologies respects your privacy and understands that personal information must be collected by lawful and fair means. Toward that end, this Privacy Policy explains what information will be collected by Steward Technologies when you use our Site and related services, how your information will be used, and how you control it, including how to collect, rectify, erase and export your information to another location not associated with our Site. We will treat all information in accordance with this Privacy Policy unless you have otherwise given us your express authorization to do otherwise. That authorization may be withdrawn at any time by notifying us at support@gosteward.com. However, Steward Technologies may use or disclose your information when we believe it is necessary for us to comply with a court order or other legal process.

Information We Collect About You

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.

How We Collect Personal Data about You

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 and our service providers may also collect information about you using various automated technologies on our Site such as those described below:

  • Cookies (or browser cookies). A cookie is a small text file placed on the hard drive of your computer. You may refuse to accept cookies by activating the appropriate “Do Not Track” setting on your browser or delete or “flush” all cookies stored on your device. However, if you select this setting or delete all cookies you may be unable to access certain parts of our Site or certain features of our Site may be disabled. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site. Cookies placed on your computer by our Site are called “first-party” cookies, and those placed by third parties are referred to as “third party” cookies. We use cookies for purposes such as tracking user visits, tracking webpages viewed, storing user preferences, gathering statistics on the number of users or visitors to our Site, implementing automatic authentication (which allows users to sign in to their accounts without having to enter their password every time), and analyzing parts of our Site in order to improve its speed, performance and functionality.
  • By visiting or registering for our Site, you consent to our use of first-party and third-party cookies and other automated technologies that we or third parties may use to collect information from our Site.
  • Web Beacons. Some pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages of our Site and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Log File Data. Log files are automatically reported by your web browser and may include information such as your Internet protocol (“IP”) address, frequency and timing of clicks you make on webpages, browser type and configuration, or webpages viewed or visited. This information helps us with improving our Site.
  • Analytics. We may use analytics programs and service providers, such as Google Analytics and Mixpanel, which can use first party cookies to report on your interactions with the Site. Google Analytics and Mixpanel collect information including, but not limited to, the time of each of your visits to the Site, whether you have visited the Site before, what website referred you to the Site, and what pages you viewed on the Site. You can also choose to opt-out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout or, with regard to Mixpanel’s automatic collection of data, by visiting https://mixpanel.com/optout.

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.

This Privacy Policy does not cover the collection of Personal Data by cookies or other methods by third parties. Any information submitted by you to a third party will be controlled by that third party’s privacy policy. We do not control how these third parties collect information or by what means such third parties may use their own cookies to collect information about you. We encourage you to review the privacy policy of any third party before submitting your Personal Data.

How We Use Information We Collect About You

Steward Technologies will use information collected about you in a way that is consistent with this Privacy Policy. When we process and share personal data about you for our own use or make it available to the recipients described below, we do so either with your consent or in furtherance of our legitimate interests, which include providing the website features that you use, operating our business, meeting our contractual and legal obligations, and protecting the security of our systems and our customers. Except as may result from a transaction described in the “Transfer of Your Information” section below, we do not rent or sell your information to anyone. We will use information you provide to us, including Personal Data, to better serve you and enhance your experience with our Site and other purposes described in this Privacy Policy that we regard as being in our legitimate interests. This may include having to modify or copy such Personal Data, or other information such as images or textual content you provide, in order to provide you with a seamless and enjoyable experience in using our Site. Please refer to the section above entitled “How We Collect Information about You” for the respective uses we make of web beacons, log file data and analytics.

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.

In addition to other uses described in this Privacy Policy, your Personal Data will be used to facilitate activities such as (1) maintaining communications; (2) verifying identities; (3) facilitating payments and other transactions (shared with third-party provider Dwolla, Inc. ("Dwolla"); (4) guarding against potential fraud; (5) performing statistical analysis and market research; and (6) if necessary, to work with affiliates and third parties to enforce our legal agreements, including working with any third-party service providers.

In addition to other uses described in this Privacy Policy, the Personal Data will be used by those entities seeking equity or debt financing (sometimes referred to as “issuers” of securities) as well as individuals or entities providing such financing to users of our Site (“investors” or “securities purchasers”) to facilitate activities such as: (1) maintaining communications; (2) carrying out regulatory checks; (3) verifying identity, including working with third-party service providers; (4) facilitating payments and other transactions (shared with third-party provider Dwolla); and (5) posting an investor profile on our Site, which may include Personal Data such as name, relationship to the issuer of securities, if applicable, and photo (if provided).

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 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 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.

Transfer of Your Information

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.

Cross Border Transfers. As stated under the “Security” section of this Privacy Policy, information you provide to us is encrypted and stored securely on private cloud servers through third-party service providers that we use in the United States. These server entities are contractually obligated to us to have redundancies in place to protect the data should an outage or other issue arise. Our objective is to ensure that your Personal Data is processed according to the provisions of this Privacy Policy and the laws of the jurisdiction in which the data is stored.

The European Commission is authorized under the General Data Protection Regulation (“GDPR”) to determine whether a particular country affords Personal Data an adequate level of protection, based on such factors as the data-protection laws in effect in that country, the existence of an independent body with enforcement powers, and the international commitments that the country has made regarding the protection of Personal Data. The Commission has determined that the US offers adequate protection, but only with respect to the Privacy Shield framework, discussed below. We are committed to ensuring that your data enjoys the rights and protections described in this Privacy Policy whenever it is transferred from the European Economic Area and Switzerland to the United States. We employ various safeguards to do so, including the use of standard data-protection clauses approved by the European Commission. Those clauses may be found at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en(the page of the European Commission’s website entitled “Model contracts for the transfer of personal data to third countries”).

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 support@gosteward.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.

Third Party Websites and Services

Steward Technologies’ Site may contain links to other websites and services not maintained by us. In addition, other websites and services may also reference or link to our Site. These other websites are not subject to our Privacy Policy and we are not responsible for their content or for the policies or practices they apply to the treatment of your information. We encourage you to be aware of this when you enter or leave our Site, and to read the privacy statements of each website that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of, other websites or services.

Opt-out Policy

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: support@gosteward.com 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.

Accessing, Changing and Otherwise Controlling Your Personal Data

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 support@gosteward.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 support@gosteward.com.

You will be able to view all of your own information that you submit. Certain highly sensitive information (such as your Social Security Number or bank account numbers) may be blocked for security reasons with only the last four digits displayed. You will, subject to our Site’s Terms of Use, be able to access, update and modify the information concerning your account by visiting your profile page and editing certain information you wish to change. For example, you will be able to change your e-mail address, your notification preferences, password, contact information, or other login information by visiting your account’s settings page.

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 are not responsible for removing your Personal Data from the lists of any third-party websites or other third parties who have previously been provided your information in accordance with this Privacy Policy.

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.

Social Media Widgets

Our Site may include certain social media features, such as the Facebook “Follow Us” button and widgets, such as the “Share This” button or interactive mini-programs that run on our Site. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the third-party website providing such features.

Security

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.

Children’s Privacy Policy

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 support@gosteward.com.

Changes to This Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. Any changes or updates will be effective immediately upon posting to our Site. If we make any material changes to our Site we will take commercially reasonable efforts to notify you by email (sent to the e-mail address specified in your account) or by means of a notice posted on our Site. Notwithstanding that, you should review this Privacy Policy regularly for changes, and you can determine if changes have been made by checking the effective date at the beginning of the Privacy Policy. Your continued use of our Site following the posting of any modified versions of this Privacy Policy means you accept those changes, and agree to be bound by the updated Privacy Policy.

Your Rights Regarding Any Complaints You May Have About Our Protection of Your Personal Data.

The Steward Technologies Site is maintained in the United States. By accessing our Site, you consent to and authorize the export of your Personal Data to the United States and its storage and use as specified in this Privacy Policy.

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 support@gosteward.com.

Please check back regularly for updates to this Privacy Policy. If you have any questions regarding this Privacy Policy, please email us at support@gosteward.com.