Privacy Policy

 

Privacy and personal information are very important to ENVST, and we take it seriously. ENVST has a mission to foster safe, secure and trustworthy transactions in shares and other securities of non-public companies, as well as other alternative assets (the “Transactions”). Doing so requires a commitment to the privacy of our community.

This Privacy Policy describes the policies and procedures of ENVST and its various affiliates (collectively, the “ENVSTGroup”, “us”, “we”, etc.) regarding the collection, use, processing, storage and transfer of non-public personal information concerning individuals who use the site www.ENVST.com and related websites and software applications (together, the “Site”), as well as the software platform, marketplace, trade sheet, and other functionality and services available on the Site (collectively, the “Services”). This Privacy Policy applies to both information that is unique to you and may be used to identify you (“Personal Information”) and also applies to Personal Information collected by us that has been subsequently anonymized or aggregated. This Privacy Policy explains how we collect, use, process and transfer your Personal Information.

By accessing the Site, using the Services, registering and continuing as a “Site Member” of the ENVST community (as described in our Terms of Use), or agreeing to provide Personal Information to another party who, in accordance with your agreement with such other party, may share such Personal Information with ENVST, you consent to our collection, use, processing, storage and transfer of your Personal Information in accordance with this Privacy Policy. We will not use, process or transfer your information except as described in this Privacy Policy without obtaining your prior consent. This Privacy Policy is also incorporated specifically by reference in our ENVST Terms of Use agreement, and any other contracts you may enter into with the ENVST Group. If you are using the Services on behalf of a business organization or other entity, or a client (such as a fund or holding company you may manage or advise, a trust, or a joint account), this Privacy Policy is nevertheless personal to you as an individual, and does not apply to that organization, entity, or client or any information relating to that organization, entity or client.

This Privacy Policy is intended to meet our obligations and duties relating to Personal Information under the legal and regulatory requirements of the jurisdictions in which we operate, including but not limited to, Hong Kong, the European Union and the State of California, USA.

We will post any updates to this Privacy Policy on this page. From time to time, it may be necessary for you to supply us with further information, including Personal Information, in connection with the Site and the provision of the Services. Failure to supply such information may result in you being unable to use the Site or Services. If at any time you do not agree with this Privacy Policy, please discontinue your use of the Site or Services.

How and why we collect Personal Information

We collect Personal Information from and about you to:

  • Set up your user account, correspond with you, and otherwise enable and facilitate your usage of ENVST Services or as is necessary for your use of the Site and the provision of the Services.

  • Help you discover, bid for, agree to, close, and otherwise participate in Transactions, as well as buy, sell, and otherwise enter into and service the securities and contracts that are issued as part of the Transactions, including but not limited to, enrolling you as a client of our affiliated brokerage(s) in connection with a Transaction.

  • Assure us, and parties to the Transactions, of the valid issuance, ownership, vesting status, transferability, and other attributes of securities issued by third party private companies (the “Stock”).

  • Verify your identity, your status as a professional investor, an accredited investor or qualified purchaser (or other qualifications), if applicable, process diligence checks, and establish your eligibility and suitability for being a member of the ENVST community.

  • If you are using the Services on behalf of an entity, organization, or client, verify your affiliation and that you are authorized to do so.

  • Setup and maintain accounts for sending and receiving funds and for depositing, holding and transferring securities.

  • Facilitate your and our compliance with various laws, regulations, and industry oversight pertaining among other things to banking, financial information, securities transactions, money laundering, terrorism, and “know your customer” rules promulgated by, among others, applicable government and regulatory bodies.

  • Create and maintain your account profile.

  • Provide you with information about, and solicit your further participation in, the Services (which may include research and development purposes and direct marketing activities and/or the transfer of your Personal Information to third parties for their direct marketing purposes).

  • Study, test, and improve the Services, and the overall user experience using the Services.

  • Offer customer support, technical support, maintenance, and product development.

  • Protect against fraud, Site misuse, privacy and security breaches, securities and other legal and regulatory violations, and to fulfill and enforce agreements reached with you and others.

We ensure that all uses of your Personal Information have one of the foregoing legal bases: Personal Information (i) that is necessary to provide the Services, including customer support, personalized features, and safety and security protections, (ii) for which we have a legitimate interest not overridden by your data protection interest, such as research and development, marketing, and protecting our interests, (iii) to comply with our legal and regulatory obligations, or (iv) where you have given prior consent to such collection and use, which you may withdraw with respect to further processing.

We collect information by asking you to enter information (including Personal Information) into forms, by observing your account activity and usage of the Services, by logging your access and activity on the Site, by your uploading of documents, and via third party information providers that, among other things, provide background checks to verify your identity, creditworthiness, and your eligibility and suitability to participate in Transactions. Third party information providers include, among others: credit reporting agencies, social media sites, our affiliated entities, fund administration partners, advertising platforms, data brokers and other data sources, and compliance service providers.

If you register or use the Services through a third party site or application such as AngelList, Facebook, or LinkedIn, or link your ENVST account to those sites and applications, we may collect Personal Information from them. We may also collect Personal Information by direct communication with you and others by telephone, in person, and by online or electronic messaging means both on-Site and through off-Site services.

We may retain or delete your Personal Information according to our internal data retention policies as permitted by applicable laws and regulations, even after you no longer use the Site and Services or terminate or deactivate your account or your relationship with ENVST, among other things for backup, archival, contract enforcement and dispute resolution, auditing, and regulatory compliance purposes.

Types of Personal Information that we collect

  • Your name and contact information.

  • As applicable and with your consent, your bank account information, money transfer instructions, age / date of birth, and social security number, taxpayer ID number, or federal employer ID number.

  • Account and identity information with respect to funds transfer accounts.

  • Financial information with respect to your investment objectives and means, including information about your wealth and financial situation, equity compensation and prior investments.

  • Service usage and Transaction history (including among other things bids, asks, negotiations, failed, abandoned, rejected, and otherwise uncompleted Transactions), as well as records of your communications with ENVST and customer service requests. When you list, bid, ask, or otherwise indicate an interest in a Transaction, we provide information about your availability and offers, in anonymized form except as described below, unless you agree otherwise.

  • Information requested or required by regulatory or governmental authorities or law enforcement bodies.

  • In connection with certain Transactions, we gather documents pertaining to your ownership of Stock if you are a shareholder, including any documents you choose to upload. The types of documents we ask for include employment, stock purchase, option, and vesting agreements you may have with the company that issued your Stock, as well as company-related documents that may be considered confidential. We also keep records of the Transactions and Transaction documents. We may also have, or solicit, applicable documents from the issuer of the Stock, or from third party reporting services.

  • Information about your affiliation with the issuers of Stock you may own or purchase, or with any organizations, securities professionals, entities, or clients on whose behalf you are using the Services.

  • Information from you about third parties that is not your own Personal Information, such as information about the company that issued Stock you hold (if a shareholder) or about your investment entity (if an investor).

  • Behavioral and marketing information such as your interests, and your public social media presence.

  • If you invite others to use ENVST, we may retain Personal Information related to your referral.

Our online software also automatically collects information from your computer, browser, phone, or other devices and software used to access the Services, and logs this information in log files. This information includes among other things your device ID, ISP, IP address, user IDs and access tokens for third party sites such as AngelList, Facebook, and LinkedIn, information you have authorized a third party to share, and any information you have made public on those services.

We generally do not collect Personal Information about your race, ethnicity, religious or philosophical beliefs, sexual orientation, health information, trade union memberships, etc., and will not do so without asking for your further, explicit consent.

 

Your Rights regarding Personal Information

You have the right to do the following:

  • Request to access your Personal Information and obtain information regarding the processing of your Personal Information, subject to applicable laws and regulations, including transferring to you or to a third party you choose, a copy of any automated Personal Information you provided consent for us to use, in a structured, commonly used, machine-readable format, in accordance with applicable legal and regulatory requirements.

  • Correct your Personal Information, including any incomplete or inaccurate information, subject to applicable laws and regulations.

  • Erase your Personal Information in certain circumstances (e.g. where there is no good reason for us to continue using it).

  • Object to or request that we restrict our processing of your Personal Information, including deleting or removing it, even in cases where we have a good reason to use it, based on something particular to your situation, subject to our legal and regulatory obligations as described above.

  • Withdraw any consent you have previously given to us with respect to the Personal Information.

  • Opt out from direct marketing at any time and without charge via the opt-out links on any marketing message sent to you, via your account settings if a Site Member, or by contacting us directly.

  • Require us, at any time and without charge, to cease to provide your Personal Information to any other person for use by that other person for direct marketing and to notify any person to whom your Personal Information has been so provided to cease to use such Personal Information for direct marketing.

  • Ascertain our policies and practices in relation to Personal Information and be informed of the kind of Personal Information held by us as well as the main purposes for which Personal Information held by us is or is to be used.

  • Depending on your jurisdiction, you may have the right to lodge a complaint with applicable regulatory bodies if you think that any of your rights relating to your Personal Information has been infringed by us.

The above functions should be available on the Site, or else by contacting us at the addresses stated in this Privacy Policy. Please note that we have the right to charge a reasonable fee for the processing of any Personal Information access request, to the extent permitted under local laws and regulations.

Note, however, that securities law and regulations, among other things, may require that we keep an archival / recordkeeping copy of some or all of your Personal Information, that we provide such information to regulatory authorities, and that removing, deleting, erasing, suspending processing of, or withdrawing consent with respect to your Personal Information may result in our no longer being able to provide you the Services.

 

Parties with whom we share Personal Information

Like any company, we may share Personal Information that we have collected with our affiliates and third parties (whether located within or outside your jurisdiction) for the purposes described above. This includes:

  • The other party or parties to a prospective or actual Transaction through the Services.

  • Intermediate entities such as funds and “special purpose vehicles” that handle securities pools on behalf of ENVST or on their own account, as well as the organizers, managers, and fund advisers of these entities or other parties in order to complete, service and enforce the terms of a Transaction or contemplated Transaction.

  • If you become a security-holder or otherwise enter into a Transaction with a third party company, that company will have Personal Information about you, and subject to their own privacy policy, may be required to disclose that information to their own investors, board, and officers, and shareholders.In the event of a reorganization, restructure, sale of a business unit, asset sale, merger with another company, public or private offering of our stock, creation of a subsidiary or a parent holding company, creation of a trust or other affiliated entity or other corporate transaction affecting the ENVST Group, or our entry into negotiations to do the same, we may share private information (which may include Personal Information) with other parties to those transactions and such parties’ advisors and representatives on a need-to-know basis under assurances of confidentiality.

  • We may create, acquire, or otherwise partner with parent, subsidiary, or affiliate business entities, trusts, or other business entities for purposes of offering the Services, issuing and holding securities, brokering and issuing securities, and servicing any notes or other instruments relating to Transactions, who may use the Personal Information under and consistent with the terms of this Privacy Policy.

  • If we are under a subpoena, court order, investigation, audit, reporting requirement or other legal or regulatory obligation, we may be required to disclose Personal Information as a matter of legal or regulatory process to any local or foreign regulatory, governmental, tax, law enforcement or other agencies or authorities for the purposes of complying with any law, rule, regulation or guideline.

  • Any affiliate, adviser, contractor, agent or third party service provider (including but not limited to affiliated broker-dealers, financial institutions and payment providers) who provide us with services relating to administration, telecommunications, payment, clearing, audit, accounting, risk management, credit, legal, compliance, operations, sales and brokerage, marketing, relationship management, securities management, information technology, records and data storage, performance measurement and compilation and analysis in connection with our provision of the Site and Services and our operations. For the avoidance of doubt, aggregated or anonymized data is no longer considered Personal Information for the purposes of this Privacy Policy, if it no longer directly or indirectly reveals your identity. Such aggregated or anonymized data that does not identify you may be shared with the foregoing persons, among others, for purposes of marketing, research and as part of our Services to the ENVST community, in order to evaluate and describe market pricing, or as a service to others.

  • Our service providers who provide us with security, fraud prevention, marketing technology, information technology, site analytics, site maintenance, software development, electronic signatures, identity verification and other Site and service features, provided that all such parties will be under confidentiality duties to protect and not share any Personal Information we give them.

  • Our affiliated broker-dealers in order to enroll you as their client. Please note that these brokerages may have their own privacy policies and client agreements, which they will disclose to you at the time of your enrollment and participation.

  • Our affiliated custodial organizations in order to enroll you as their client. These organizations may have their own privacy policies and client agreements, which they will disclose to you at the time of your enrollment and participation.

  • Members of the ENVST community, if you have chosen privacy settings that indicate you wish to share some or all of your profile, status or experience to such members.

  • To third parties you agree or ask us to disclose Personal Information to.

  • Any other person under a duty of confidentiality to the ENVST Group or its affiliated entities that have undertaken to keep such Personal Information confidential.

Although we sometimes refer to affiliates as “we” or part of the Services, please be aware that some of these entities are not under common ownership with, or controlled by, ENVST. All securities transactions (including any solicitation, engagement, brokering, closing, and clearing Transactions) are handled by affiliated broker-dealers. Further, per the terms of the Transactions and other agreements you may enter into, ENVST may setup or contract with third parties to service, pool, and otherwise manage the securities that are the subject of the Transactions.

 

Cookies

When you access the Site or Services, we may place cookies, pixel tags, web beacons, page tags, or other data-gathering and transmitting tools or files on your device. These help us recognize you as a user, customize and personalize the Services, study and improve our offerings, collect information about your device and software in order to improve Site performance or prevent fraud. Most Internet browsers and other access software are able to disable or remove these cookies, and will contain instructions on how to do so, but doing so could affect your ability to use the Site and Services.

Age restrictions

The Site and Services are directed at and intended solely for adults according to the age of majority and other laws of their jurisdiction. We do not knowingly collect any information from anyone under the age of 18 or allow them to use the Site or Services. If you learn that we may have inadvertently collected any such information, please contact us immediately for a resolution.

 

Other sites and services

ENVST may refer you to third parties, via links from its Site or Services, communications from ENVST, or otherwise. These include among others any banks, payment processors, electronic signature services, brokerages, educational and informational sites, and transfer agents. ENVST is not responsible for the privacy policies and practices, performance, or terms of use and other contracts offered by these third parties, and does not endorse, provide, or provide any warranties with respect to any content or services they offer you. Please remember that when you go to another website or other service, that service may have its own privacy policy that applies in place of or in addition to ours.

 

How we protect your Personal Information

ENVST is committed to maintaining the confidentiality, accuracy, and security of the ENVST community’s Personal Information, to honor our clients’ integrity, respect the trust the ENVST community places in us, and for purposes of compliance.

We protect Personal Information by using software, physical safeguards, and internal procedures, in compliance with applicable laws and regulations. This includes using secure servers, encryption, and locked facilities as applicable. We maintain access policies designed to limit access to Personal Information to those who need to know as part of the Services, and education and training for employees on the importance of confidentiality. We have a policy of requiring companies that work with us to protect Personal Information as well.

We ask you to help by taking reasonable precautions to protect your own files, use secure passwords, and generally exercise due care with any sensitive information about yourself or other people.

No security system is completely without risk. If there is a security or data breach affecting your Personal Information, we will attempt to investigate and as appropriate, notify you and take other applicable legal steps. Further, if you become aware that any Personal Information we have appears to be inaccurate, and you are unable to correct it yourself from your user account, you may contact us as described below. You may also contact us anytime if you have questions regarding your Personal Information, the Services, or any other matter.

 

Contacting Us

ENVST is the “controller” of your Personal Information. ENVST is the contact for all matters related to this Privacy Policy, including without limitation, any complaints or requests for access to and correction of your Personal Data.

You may contact Stephen Lin, under the direction of Chief Compliance Officer at 2708 Wilshire Blvd Suite 380 Santa Monica, CA 90403, or INFO@ENVST.com.

All non-US clients, including those in the European Union and Asia-Pacific, should use the above contact addresses for any questions, issues, or requests regarding their Personal Information and this Privacy Policy. If you believe we have not adequately responded to any request or resolved any complaint, you may have the right to contact your local governmental or regulatory body to file a complaint.

Policy Changes

This Privacy Policy may be amended from time to time at any time. For the purposes of any such amendments, our posting of a revised version of the Privacy Policy, with an updated version number and/or date, is to be considered adequate notice to you of the amendment. Any revised version will be effective as of the time posted to the Site, or otherwise noticed to you. Therefore, you should review this Privacy Policy periodically. We may require you to affirmatively assent to any revised version of this Privacy Policy as a condition for continued use of the Site or Services or as required by relevant laws or regulations.

Transfer of Personal Information Between Jurisdictions

Our collection, holding, processing or use of your Personal Information in accordance with this Privacy Policy may (whether in whole or in part): (i) take place outside of the jurisdiction in which you reside, or (ii) be controlled by a party whose principal place of business is located outside of your current jurisdiction, where there may not be in force any data protection law which is substantially similar to, or serves the same purposes as, the data protection laws in your current jurisdiction. This means that your Personal Information may not be protected to the same or similar level as in your current jurisdiction.

You understand and agree that your Personal Information may be transferred outside of your current jurisdiction, where such jurisdiction which may or may not provide the same level of protection for personal data.

Use of Personal Information in Direct Marketing

We intend to use your Personal Information for direct marketing and we require your written consent (or an indication of no objection) for such purposes. In relation to this, please note that:

  • The Personal Information stated under the section titled "Types of Personal Information that we collect" of this Privacy Policy may be held by us from time to time and may be used by us in direct marketing.

  • The following classes of services, products and subjects may be marketed: employee liquidity programs and related services, private placement services, market monitoring services and trading services.

  • The above services, products and subjects may be provided by or solicited by us and/or our affiliates, third party financial institutions, and/or their agents.

  • In addition to marketing the above services, products and subjects, we also intend to provide the Personal Information described in the section titled "Types of Personal Information that we collect" of this Privacy Policy above to all or any of the persons described in the section titled "Parties with whom we share Personal Information" of this Privacy Policy for use by them in marketing those services, products and subjects, and we require your written consent (or an indication of no objection) for that purpose.

  • In connection with the immediately preceding paragraph, we may receive money or other property in return for providing the data to the persons described in the section titled "Parties with whom we share Personal Information" of this Privacy Policy for use by them in direct marketing (including revenue / benefit sharing arrangements between us and such persons).

We will, when using your Personal Information in direct marketing for the first time, inform you that we will, without charge to you, cease to use the Personal Information in direct marketing if you so require. If you do not wish us to use and/or provide to other persons your Personal Information for use in direct marketing as described above, you may exercise your opt-out right by contacting us at the addresses given above.

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