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We are committed to protecting your privacy and preserving your trust. Please carefully review this Privacy Policy.
Privacy Policy
Last Updated February 1st, 2024
This privacy policy (“Privacy Policy”) provides transparency about our privacy practices, including how OpenDeal Inc. and its subsidiaries, including but not limited to, OpenDeal Portal LLC dba Republic, Republic Crypto LLC dba Republic Advisory Services, Republic Core LLC, OpenDeal Broker LLC dba Capital R, Fig Publishing, Inc., Republic Investment Services LLC (f/k/a NextSeed Services LLC), Republic Markets Jersey Limited, Republic Node Jersey Limited, and Republic Deal Room Advisor LLC (together “Republic,” “we,” “us,” and “our”), collect, process, and disclose any Personal Information, and how you can control and manage your privacy choices.
In this Privacy Policy, a “user” or “you” refers to any of the following: (i) visitors of Republic and its affiliates’ websites (e.g., https://Republic.com) (collectively, the “Republic Platform”), (ii) individuals who interact with Republic or its Services (as defined below), and (iii) individuals who create an account on the Republic Platform, including “Issuers” and “Investors” (collectively, “Users”). You acknowledge and consent to our privacy practices as described below.
This policy contains the following sections:
- Scope and Applicability
- Information We Collect and Receive
- Our Uses of Personal Information
- How We Share Information
- Communications and Marketing
- Data Retention and Disposal
- Cookies and Other Identifiers
- Third-Party Sites, Blogs, and Social Media
- General Data Protection Regulation and International Transfers
- California Residents
- Your Privacy Preferences
- Children’s Data
- Republic Investment Services LLC
- Information Security
- Breach Notification
- General Inquiries and Updates
1. Scope and Applicability
The scope of this Privacy Policy applies to Republic and any of our affiliates with whom we may share Personal Information, and encompasses all of our Services (operated offline, online, or both) including services made available through the Republic Platform (which includes websites, applications, and online services) including, but not limited to, our advisory consulting and offering support Services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels.Our relationship with you will determine how this Privacy Policy applies to you and your information. In general, if you engage with us directly and independently of a third party, this Privacy Policy applies. To the extent that your information is processed by an independent third party (e.g., identity verification provider), then that third party may be responsible for your privacy with respect to that information. If you have any question as to who is responsible for your information, you may contact privacy@republic.com.
2. Information We Collect and Receive
Registered Users—Registered Users are persons who sign up and create a user account with us via the Republic Platform. We may collect the following Personal Information from Registered Users:
- Your name;
- Your email address;
- Your username;
- Your password(s);
- Your Facebook information if you are signing up via Facebook connect (this will authenticate your identity and link your Facebook Profile information, such as your name, profile image, and email address, to your account);
- Your address or geographic location; and
- Your profile image;
- Optional Demographic Information including, but not limited to; sexual preference, gender, ethnicity, age, veteran status, disability status, immigrant or refugee status.
Investors—Investors are Registered Users (whether natural persons or entities) who have applied to participate in investment opportunities using the Republic Platform. We may collect the following additional Personal Information from Investors:
- Legal physical address;
- Telephone number;
- Date of birth;
- Business name, address, email, phone number, and names of owners and management, if applicable;
- Balance sheets, profit and loss statements, bank account information, average bank balance, bank statement and other financial data, including tax returns, as applicable, in order to help verify your accreditation status or "Qualified Purchaser" status;
- Tax ID number or social security number, as applicable, citizenship status, and state or country of formation for investment entities, if applicable;
- Responses to further questions answered during the profile creation; and
- Further information in order to help validate your identity such as your driver’s license information or government issued identification number.
Issuers—Issuers are Registered Users who have applied to raise capital via a registration exemption using the Republic Platform. We may collect additional information (e.g., financial and reputational due diligence) as well as that which we would collect from an Investor.
Republic Event Attendees—Event Attendees are persons who sign up to attend an event via a Republic invitation. We may collect the following Personal Information from Event Attendees, if you engage with us through our contact methods:
- Your name;
- Your email address;
- Your mailing address.
- Other Webform Data: information collected when you engage with us through our webforms, surveys and questionnaires, blogs, discussion forums, or live chat.
3. Our Uses of Personal Information
We use Registered User Information to:
- Operate and provide you with the Services;
- Communicate with you and send you marketing communications;
- Keep your account secure and protect our Platform, Service, and other Users;
- Analyze your preferences, interests and behavior in order to provide you with tailored content and the most relevant content and communications; and
- Enforce our Terms of Service, enforce our legal rights, comply with applicable law, and respond to government and legal requests.
- To determine demographics of platform usage
We use Investor and Issuer Information to:
- Verify your identity and status with respect to securities and other laws;
- Facilitate your payment and any escrow of funds;
- Record your investment with our third-party SEC-registered transfer agent;
- Provide you with necessary tax reporting information; and
- For other purposes for which we provide specific notice at the time of collection of the information.
We use Republic Event Attendee Information to:
- Communicate with you and respond to your event registration;
- Provide you with necessary event information; and
- Send post event communications.
Lawful Basis for Processing. Depending on your circumstances and your relationship with us, we may process your Personal Information on the following lawful bases:
- Consent: where you have given consent to the processing of his or her Personal Information for one or more specific purposes;
- Contract: where the processing is necessary for the performance of a contract with you (e.g., to deliver the service you have requested);
- Legal Obligation: where processing is necessary for compliance with a legal obligation to which the controller is subject (e.g., for compliance with securities laws); and
- Legitimate Interests: where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, not overridden by the interests or fundamental rights and freedoms of the data subject, (e.g., for product development and analytics purposes).
4. How We Share Information
Republic shares and discloses Personal Information to other parties as needed to provide our Services and operate our business. The categories of other parties with whom we may share information include:
The Republic Family of Companies - Affiliates and Subsidiaries. Republic may share Personal Information about you with affiliates and subsidiaries.
Service Providers. We may share the information that you have provided us with certain third party services, including payment processors, web services providers, developers, security and storage service providers, analytics service providers, and providers used to analyze our websites’ and applications’ functionalities.
Business Services. We may share any category of Personal Information with our business services providers in the operation of our business and facilitation of the Services, including agents, auditors, financial institutions, and professional advisors.
Corporate Activities. We may share any category of Personal Information with other companies or entities as part of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock. In such case your Personal Information may be transferred to the potential or actual acquirer, successor, or assign.
Government and Legal. We may share any category of Personal Information with other parties, including public authorities, as may be required by applicable law, regulation, or legal process.
5. Communications and Marketing
When you sign up for our Services, we may send periodic email and text communications to you regarding the Services or tell you about new Services we believe will be of interest to you; generally, such notices will specify which member of Republic has sent it to you. You may also subscribe to our blog and newsletter or sign up to hear about investing opportunities. You can also opt out of promotional or marketing email or text communications, including affiliate marketing, by following the unsubscribe instructions in any email or text communications you receive from us, by accessing your notification settings by logging into your account, or by contacting us at privacy@republic.com. Please note: Opting out will not unsubscribe you from important communications regarding your Republic Platform account, security related matters or those notices required by applicable law.
6. Data Retention and Disposal
Republic retains Personal Information in accordance with its data retention policies consistent with applicable law. Certain Personal Information subject to record retention requirements (e.g., under SEC and FINRA rules and regulations) may be retained for at least 7 years for legal and compliance purposes, as well as with respect to relevant statutes of limitations.
7. Cookies and Other Identifiers
We use cookies throughout our websites and web applications to track user interactions, personalize your user experience, and promote our Services. Cookies are small files stored on a computer that are designed to hold small amounts of data specific to a user and the websites or applications to help tailor that user’s experience. For more information, please see our Cookies Disclosure.
8. Third-Party Sites, Blogs, and Social Media
Our website includes links to other websites whose privacy practices may differ from ours. When you use a link to go from our website to an unaffiliated website, the privacy policy of the other website will apply.
Our website offers a publicly accessible blog. Information you provide in relation to blogs, including comments, may be displayed publicly and read, collected, and used by others who access them. To request removal of your Personal Information from our blog, contact us at privacy@republic.com. In some cases (e.g., comments made on a Deal page that must be retained by law), we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
Our website includes 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 website. These features may collect your IP address, which page you are visiting on our website, 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 website. Your interactions with these features may also be governed by the privacy policy of the company providing such feature.
9. General Data Protection Regulation and International Transfers
International Transfers. Republic is based in the United States and your Personal Information may be collected and processed in the United States. Republic has affiliates outside of the United States. If transferred, data is transferred subject to appropriate transfer mechanisms and safeguards.
Privacy Rights of UK, EU/EEA, and Swiss Data Subjects. If you are a located in the UK, EU/EEA, or Switzerland, subject to certain limitations, you have the following data protection rights:
- Withdrawal of Consent. If processing is on the basis of consent, you have the right to withdraw consent to the processing at any time.
- Access and Rectification. You have the right to access, correct, and update your Personal Information.
- Deletion/Erasure. You have the “right to be forgotten” through the erasure or deletion of your Personal Information.
- Portability. You may have the right to move, copy, and/or transfer certain Personal Information from our service to another service.
- Stop Processing. If processing is on the basis of legitimate interests, you have the right to object to the processing of your Personal Information and to ask us to restrict the processing of your Personal Information, subject to certain limitations.
- Submit a Complaint. You have the right to submit a complaint to a data protection authority about our collection and use of your Personal Information. Contact details for the UK data protection authorities is located here, for the EU/EEA here, and for Switzerland here.
You may exercise many of your rights through your account or by submitting a request to our Data Protection Officer at privacy@republic.com. We will process verified data subject requests within 30 days. If we require more time, we will inform you of the reason and extension period in writing. Please note that requests are subject to appropriate verification before processing.
10. California Residents
Privacy Rights of California Residents. If you are a California resident, under the California Consumer Privacy Act (“CCPA”) and its successor, the California Privacy Rights Act (“CPRA”) you have additional rights regarding your Personal Information. Subject to certain limitations, your rights include:
- Right to Know. You have the right to know and see what Personal Information Republic has collected about you over the preceding 12 months, including:
- the categories of Personal Information Republic has collected about you;
- the categories of sources from which Personal Information is collected;
- the purposes for collecting your Personal Information in accordance with the Services;
- the commercial purposes for collecting your Personal Information;
- the categories of third parties with whom Republic has shared your Personal Information; and
- the specific pieces of Personal Information Republic has collected about you.
- Right to Deletion. You have the right to request that Republic delete the Personal Information we have collected from you. However, there are exceptions under which we may retain your Personal Information and where we are not required to delete your Personal Information.
- Right to Correction. You have the right to request that Republic correct the Personal Information collected from you.
- Right to Portability. You may have the right to request that we transfer certain Personal Information to another entity, subject to certain exceptions.
- Right to Opt-Out of the Sale or Sharing of Personal Information. We do not “sell” or “share” Personal Information as defined by the CCPA or the CPRA. You have the right to opt out of any processing for purposes of cross-context behavioral advertising, targeted advertising or profiling in connection with decisions that produce legal or similarly significant effects, if applicable.
- Right to Opt-Out of Automated Decision-Making. You have the right to opt out of automated decision-making, if applicable.
- Right to Opt-Out of the Use and Disclosure of Sensitive Personal Information. If we collect sensitive Personal Information, we will restrict its use to what is necessary to perform the Services requested by you.
- Right to be free from discrimination. You have the right to be free from discrimination for exercising your rights under the CCPA/CPRA.
If you are a California resident and would like to exercise your rights in accordance with the CCPA, you may contact Republic using any of the following methods:
- Via email at privacy@republic.com; or
- Via our toll-free California Personal Information Privacy Line at (800) 634-0599.
We will process a verified California consumer privacy request within 45 days of receiving the request. If we require more time, we will inform you of the reason and extension period in writing. Please note that requests are subject to appropriate verification before processing.
11. Your Privacy Preferences
Republic may provide you the opportunity to exercise certain preferences with respect to your Personal Information, such as accessing, updating, deleting, and exporting Personal Information, by logging into your account profile or by making a request to: privacy@republic.com. Republic may, in its discretion, process such requests as a courtesy, subject to appropriate prior verification.
For registered users and investors, you can update your privacy settings via our portal at the following link: https://republic.com/settings/privacy
12. Children's Data
Republic recognizes the sensitivity of Personal Information concerning children under the age of majority (“Minors”). Our websites and Services are not marketed to Minors and we do not knowingly solicit or collect Personal Information from Minors. If you believe that a Minor has created an account or disclosed Personal Information to us, please notify us immediately at privacy@republic.com.
13. Republic Investment Services LLC
Some of your personally identifiable information and other details will be shared with both the issuer of the assets and any buyer of your sell request for the purpose of concluding any transfer of shares. For more information, please visit the Republic Secondaries Terms of Use.
14. Information Security
We take reasonable measures to protect our systems from harm and to safeguard the confidentiality, integrity, and availability of your Personal Information. Our efforts include implementing appropriate physical, technical, and administrative controls to ensure a level of security commensurate with the risk, in particular, to protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Information transmitted, stored, or otherwise processed.
15. Breach Notification
If your Personal Information is the subject of a data breach under applicable law or regulation, we will take appropriate action, including providing you with notice, as such law or regulations may require.
16. General Inquiries and Updates
For inquiries about this Privacy Policy, or to make a request or file a privacy complaint, please contact us at privacy@republic.co or at:
Republic
149 E 23rd St #1314
New York, NY 10010
Attn: Privacy Compliance
This Privacy Policy may be updated from time-to-time, so please check back regularly for updates.
This Privacy Policy was updated on February 1st, 2024.
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