Updated as of April 1, 2021
This Privacy Statement covers the following affiliated companies: Neuravest Research Inc, Neuravest Holdings LLC and Lucena Research Inc. These entities are collectively referred to as the “Company,” “we,” or “us”. We do not disclose information to non-affiliated companies except as described below.
1. Acknowledgement and acceptance of terms
The Company is committed to protecting your privacy. This Privacy Statement sets forth our current privacy practices with regard to the information we collect when you or your computer or mobile device interacts with our website. By accessing the web pages comprising this site (collectively, the “Site”) you agree with and consent to the terms of this Privacy Statement.
2. Third-party policies
This Site may contain links to other websites, or you may have been linked to this Site from another website, but this Online Privacy Statement does not apply to them and we are not responsible for their content. If you visit external websites, we recommend that you review their privacy policies. If we materially change our privacy policies or practices, we will also amend this Online Privacy Statement to reflect such changes. You should review the Privacy Statement each time you visit this Site.
The collection, further use, or disclosure of your information by issuers, unaffiliated service providers or by other third parties is not the responsibility of the Company. Such collection, use, or disclosure is governed by the third parties’ privacy policies.
3. What data is collected through this Site? Personal and technical information generally.
This Site will collect personal information that you provide, including information you provide on behalf of others. Providing this personal information represents your consent to the Company’s collection and use of such information in accordance with the Privacy Statement.
As further set forth below, this Site may also collect information about your computer and operating systems, such as your Internet Protocol address, domain name, and system configurations and settings.
Additionally, if you access a password protected portion of this Site, then: (a) once you submit your password, this Site will recognize you and will collect all information that you submit, including all electronic instructions (such as transaction information); and (b) any information collected about you from this Site may be associated with other identifying information that we have about you.
4. Technical information we collect
The Company collects technical information in five ways: directly from our web server logs; by recording web sessions; with cookies; with web beacons or GIF files; and using scripts and other tracking technology.
A. Web Server Logs:
When you visit our Site, we may track information to administer the site and analyze its usage. Examples of information we may track include:
- • Your Internet Protocol address.
- • The kind of browser or computer you use.
- • Number of links you click within the site.
- • State or country from which you accessed the site.
- • Date and time of your visit.
- • Name of your Internet service provider.
- • Web page that linked you to our site.
- • Pages you viewed on the site.
B. Web Session Recording:
The Company may use a third-party vendor to record your web sessions on the Site. The Company, through this service, records all your actions on the Site. However, personal information that you provide via the Site is not recorded and is not provided to the third-party vendor providing the recording service or to any third party unrelated to the products and services for which you are accessing the site. Use of your personal information is discussed in Section 7.
One of the primary purposes of cookies is to provide convenience features to save you time. For example, if you personalize a web page, or navigate within a site, a cookie helps the site to recall your specific information on subsequent visits. This simplifies the process of delivering relevant content and eases site navigation by saving your preferences and login information as well as providing personalized functionality.
The Company may collect, use, and share aggregated data, but does not allow other companies to place cookies on our Site except to enhance or enable full use of the site (such as merging into the Site a different site that relies on third-party cookies). You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. Most Web browsers can be set to notify you when an HTML cookie is placed on your computer. You can manually delete HTML cookies and set most browsers to refuse to accept HTML cookies, although doing so may affect your website experience. Likewise, most mobile devices allow you to disable another party’s ability to collect geo-location information from your mobile device. The help function on most browsers and mobile devices contains instructions on how to: set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to adjust these settings in each browser, on each device you use to surf the Web. Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. The Interactive Advertising Bureau website at www.allaboutcookies.org/ tells you how to remove cookies from your browser. Further details about our cookie usage are provided below. Flash cookies may be removed by managing your Adobe® Flash® Player settings. To delete or prevent placement of Flash cookies, you will need to visit the Adobe® Flash® Player Help site at http://www.adobe.com/go/settingsmanager, click on the hyperlink for “Website Privacy Settings Panel” on the left side of the screen, and follow the instructions for preventing third-party Flash content from storing data on your computer.
If you reject cookies by changing your browser settings, be aware that this may disable some of the functionality on our Site.
D. Web Beacons or GIF files:
The Company web pages may contain electronic images known as web beacons – sometimes also called single-pixel gifs – that allow the Company to count users who have visited those pages and to deliver co-branded services. The Company may include web beacons in promotional email messages or newsletters to determine whether messages have been opened and acted upon. Some of these web beacons may be placed by third party service providers to help determine the effectiveness of advertising campaigns or email communications. These web beacons may be used by these service providers to place a persistent cookie on your computer. This allows the service provider to recognize your computer each time you visit certain pages or emails and compile anonymous information in relation to those page views, which in turn enables us and our service providers to learn which advertisements and emails bring you to our website and how you use the Site. The Company prohibits web beacons from being used to collect or access your personal information.
E. Scripts and other activity tracking technology:
The Company may accommodate this technology in collaboration with its clients or other third-party sites that link to the Site, so that the third party can track activity across its domains and this Site.
5. How we use and share technical information
We may share anonymous information from the technical information sources described above with our clients or service providers to help them better understand your online activity, including information about: the effectiveness of the Site, pages viewed and time spent on specific pages, and how you were linked to the Site.
Technical information we provide is anonymous and does not include personal information. Certain third-parties who are issuers or sponsors of securities offerings may receive personal information subject to the terms below in addition to technical information. In that case, the Company and those third-parties may be able to independently attribute your technical information, including your online activity, to you individually.
6. Personal information we collect from users
For some types of transactions or registrations, we will ask for personal information – for you, your client, or both – such as name, address, email, telephone number or facsimile number, bank account number, social security number, driver’s license, passport, or other government issued identification number, income or net worth information, and other information relevant to your request for participation in a transaction. You may also be asked to disclose personal information to us so that we can provide assistance and information to you or your client. For example, we may need personal information to provide online technical support and troubleshooting. We will not disclose personally identifiable information we collect from you to non-affiliated parties without your permission, except to the extent necessary to provide the products and services, as described below.
7. How we use, share, and protect personal information
Personal information you provide and the personalized data you create and save on the website are used to provide services to you and to inform you of products, services, or opportunities that may be available through the Company. Information and data you provide will also be used to administer our business, the Site, and our products and services in a manner consistent with this Privacy Statement, the terms and conditions that govern your use of this Site, and all applicable laws, rules, regulations or other legal obligations. If you provide us with your name, address, telephone number, or email address, or have done so in the past, the Company may contact you by telephone, mail, or email. You may change your contact details or unsubscribe from mailing lists at any time by contacting us as provided below. Email or other electronic communications sent to us through this Site will be maintained in a manner consistent with our legal and regulatory requirements regarding member, client and public communications.
We do not rent, sell or share your personal information or personalized data to unaffiliated organizations except to provide products or services you have requested, when we have your permission, or under certain limited circumstances. For example, we provide such information to companies who work on behalf of or with the Company, subject to confidentiality agreements. These companies may use your personal information to help the Company communicate with you about the Company’s products and services or to assist the Company in the provision of its products and services. The Company may compile and use aggregated, anonymized data that does not directly or indirectly identify you or compromise your personal information in violation of this policy.
The Company may share information that you provide to authorized users within your organization who are also providing services on the relevant transaction. The Company may share information that you provide with the issuer and sponsor of the offering in which you have expressed an interest, the broker-dealers providing services for that issuer and sponsor, as well as other companies providing services in connection with the offering, such as escrow agents and banks, credential-checking services, the issuer’s special purpose vehicle(s) for that offering, and other financial intermediaries such as transfer agents, investment advisors, etc.
Social security numbers are only shared with the following and only as applicable to a particular transaction or activity the user initiates on the Site: personnel for third-party intermediaries processing the transaction for the issuer and sponsor; other parties that use the social security numbers for the limited purpose of providing services for the offering and that have agreed to maintain the confidentiality of your information; other financial intermediaries involved in the transaction; and the issuer and sponsor of the securities.
Information that the Company collects electronically through its Altigo platform is only shared with Company affiliate WealthForge Securities, LLC only if and only to the extent it is necessary for WealthForge Securities, LLC to provide services for an issuer or sponsor. WealthForge Securities, LLC will only use that information to the extent it is necessary to perform services for the particular offering as set forth in its agreement with the issuer and sponsor and to comply with applicable law and regulation.
The Company maintains reasonable physical, electronic, and procedural safeguards that comply with applicable laws and regulations to protect personal information about you, and works with vendors and partners to protect the security and privacy of user information. The Company’s security measures are found on [ please add link to security page here] and may be updated from time-to-time. The Company maintains the information collected on servers located within the United States and does not transfer your data to other countries.
8. Other reasons we share either technical or personal information
Finally, we may transfer information about you to any acquirer or successor of any of the affiliated companies if and to the extent that any of the affiliated companies is acquired by or merged with another company.
9. Changes to this statement
The Company has the discretion to update this Privacy Statement at any time. When we do, we will also revise the “updated” date at the top of this page. We encourage you to review this Privacy Statement each time you access this site to stay informed about our use of your information. Access or use of the site is subject to the current version of the Privacy Statement.
10. Notice to residents of California and Nevada
A. California Residents:
California law requires that we obtain your affirmative consent before we share your nonpublic personal information with non-affiliated third-party companies.
The California Consumer Privacy Act requires that the Company inform you of your rights, provide a list of the categories of personal information it has collected about consumers in the past twelve (12) months and detail what categories of personal information it sells or discloses.
Rights of California Residents
1. Right of access
California residents have the right to request that a business that collects a resident’s personal information disclose to that resident the categories and specific pieces of personal information the business has collected.
California residents have the right to request that a business that collects personal information about the resident disclose to the resident the following:
(1) The categories of personal information it has collected about that resident.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting or selling personal information.
(4) The categories of third parties with whom the business shares personal information.
(5) The specific pieces of personal information it has collected about that consumer.
2. Right to know what we sell or disclose
California residents have the right to request that a business that sells the resident’s personal information, or that discloses it for a business purpose, disclose to that resident:
(1) The categories of personal information that the business collected about the resident.
(2) The categories of personal information that the business sold about the resident and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
(3) The categories of personal information that the business disclosed about the resident for a business purpose.
Company does not sell personal information
3. Right to opt out
California residents shall have the right, at any time, to direct a business that sells personal information about the resident to third parties not to sell the resident’s personal information.
4. Right to deletion
In some cases, California residents shall have the right to request that a business delete any personal information about the resident which the business has collected from the resident.
5. Right to equal service and price
A business may not discriminate against a California resident because the resident exercised any of the resident’s rights, including, but not limited to, by:
(A) Denying goods or services to the consumer.
(B) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
(C) Providing a different level or quality of goods or services to the resident, if the resident exercises the consumer’s rights under this title.
(D) Suggesting that the resident will receive a different price or rate for goods or services or a different level or quality of goods or services.
How to request your information
To request what personal information Company has disclosed to a third party please contact Company via either https://www.neuravest.net/ – Contact US or email us at: email@example.com.
To request your personal information be deleted email the following address firstname.lastname@example.org.
Categories of Personal Information Company collects
Sections 4 and 6 above detail the categories of technical and personal information Company collects from users of this website.
Categories of Personal Information Company has sold in the past twelve (12) months.
Company acts solely as a service provider and does not sell personal information.
Categories of Personal Information Company has disclosed in the past twelve (12) months
Sections 5 and 7 above detail how Company and its Affiliates use your technical and personal information. Information provided by you in the registration and investment flow pages may also be shared with the issuer of the offering in which you have expressed an interest, third-party intermediaries providing services for that issuer, as well as other companies providing services in connection with the offering, such as, escrow agents and banks, credential-checking services, the issuer’s special purpose vehicle(s) for that offering, and other financial intermediaries. In each case, disclosure is subject to applicable privacy law and is limited to the extent the third party needs the information.
Company has disclosed the following types of personal information to third-parties in the past twelve (12) months:
- To issuers of securities: name, date of birth, accreditation status, SSN, bank account information, suitability information (including income or net worth estimates).
- To broker-dealers or advisors: name, date of birth, accreditation status, SSN, bank account information, suitability information (including income or net worth estimates) of their subscribers.
- To regulators: name, date of birth, accreditation status, SSN, bank account information, suitability information (including income or net worth estimates).
- To third-party service providers: name, date of birth, SSN, bank account information.
Any information provided to the Company will be used for the purpose of completing the transaction.
In addition, if you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by the Company to its affiliates and/or third parties for their direct marketing purposes.
To make such a request, please send an email with your first name, last name, mailing address, email address, and telephone number to email@example.com. Please include “California Privacy Rights” in the subject line of your email. You may also make such a request by writing to us at the address set forth in the Contacting Us section.
Nevada law requires us to disclose that you may elect to be placed on our internal do-not-call list by calling us at 804-308-0431. For further information, contact the Nevada Attorney General’s office at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; by phone at 702-486-3132; or by email at BCPINFO@ag.state.nv.us.
11. Notice to European Union members
Data subjects in the European Union have the following principal rights under data protection law:
- the right to withdraw consent;
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object to processing;
- the right not to be subject to decisions made solely on automated processing; and
- the right to complain to a supervisory authority.
To limit our collection, storage, or sharing please contact our Data Protection Officer, Paul Wilcox as provided below.
12. Contacting us
If you have questions regarding our Privacy Statement, its implementation, or failure to adhere to this Privacy Statement and/or our general practices, please contact us at: firstname.lastname@example.org or send your comments to:
Privacy Statement Representative and Data Protection Officer
3333 Piedmont Rd NE
Atlanta, GA 30305