PRIVACY POLICY

(Last updated July 19, 2023)

OVERVIEW

Your privacy matters to us. This Privacy Policy explains personal information the Currant collects about you when you access or use one of our Sites or Services or interact with us in response to an email or other outreach from us or through any Currant application process. This Privacy Policy also explains how we may use or disclose personal information that we collect about you.

This Privacy Policy applies to you whenever you access or use any of our Sites or Services, download anything from our Sites, or interact with us in response to an email, request for information or other outreach from us or through any Currant application process. This Privacy Policy does not govern information you choose to exchange directly with other Users of the Sites, as we have no direct control over the collection or use of that information. Please use appropriate precautions in sharing your information with such Users.

In addition to this Privacy Policy, your relationship with Currant is also governed by our Terms of Use and transaction documents you may enter into in connection with making an investment through the Sites. You should carefully review those documents and the Terms of Use.

Some Definitions

The following are definitions for some terms used in this Privacy Policy:

  • “Affiliate” means an entity that controls, is controlled by, or is under common control with Currant Platforms Inc., whether the control results from equity ownership, contract, overlapping management or otherwise.
  • “Content” refers to all text, images, photographs, graphics, logos, illustrations, descriptions, data, tools, features, apps, pages, and other materials provided on the Sites, as well as the selection, assembly, arrangement, “look and feel,” and design of our Sites.
  • “Currant,” “we,” “us,” and “our” refer to Currant Platforms Inc. and its Affiliates.
  • “Sites” refers to the domains and subdomains of our website at http://www.currant.co and our mobile applications.
  • “Services” the Content, products, or services offered on or through the Sites.
  • “User” means anyone who accesses and/or uses any of our Sites or Services.

 

Your Consent

By using or accessing any of our Sites or Services, downloading anything from any of our Sites, or by submitting information to us in response to an email or other outreach or through any Currant application process, you agree to the terms of this Privacy Policy and consent to the collection, use, and sharing of your personal information subject to and consistent with the term of this Privacy Policy and applicable laws and other notices you may receive from us.  

Changes to this Policy

This Privacy Policy is subject to change. When we make a change to the Privacy Policy, we will post the most current version of the policy here. Each time you visit our one of our Sites or Services, download anything from our Sites, or interact with us in response to an email, request for information or other outreach from us or through any Currant application process, the current version of our Privacy Policy will apply.

PERSONAL INFORMATION WE COLLECT

To help us to provide Services, we collect personal information about you through several means.

How We Collect Personal Information

Direct means. We collect personal information from you directly by asking you for it when you open an account or in other instances when you contact us or access or use any of our Sites or Services. In fact, various laws require that we collect some of the kinds of personal information we ask for, such as anti-fraud / anti-money laundering laws, and “know your customer” obligations. In addition to personal information that we are required to obtain from you by law, we may ask you for other personal information that you may, at your option, provide or withhold, and any such information provided will be subject to this policy.

Automatic or passive means. Whenever you visit, use, access, or interact with any of our Sites or Services, we use cookies and tracking technologies to collect data about you and your activities on our Sites or use of our Services automatically or passively. 

Third-party sources. We may obtain information about you from various third parties, including: (1) service providers we engage to conduct certain functions on our behalf, such as to verify the identities of the Users of our Services or Sites; (2) analytics providers, who we use to assist us better understand who is using our Sites and Services; and (3) advertising, social media and market research providers and partners whom we engage or with whom we partner for advertising, social media or market research services, as well as for referral purposes. 

Types of Personal Information We Collect

The type of personal information we collect from and about you online will depend on how you interact with us, including which of our Services you use and which of our Sites or parts of them you access. The personal information we collect from or about you may include the following:

  • Your name, residential and business address, email address, citizenship, telephone number, Social Security number, date of birth, your employment status and employer.
  • Your investment experience, objectives, and preference, as well as information to establish whether or not you are an “accredited” investor.
  • Your finances, including information regarding your bank account, net worth, and income. 
  • Access credentials you establish to receive our Services or access our Sites.
  • Information about your relationship to or ownership in any entity that uses our Services.
  • Details of any financial transactions you execute using our Services.
  • Your preferences for receiving, and how you engage with, our marketing communications.

 

In addition, we collect personal information about the devices you utilize to access or use our Sites or Services, such as: (1) your IP address or other unique identifier from the computer, mobile device, tablet, or other device you use to access any of our Sites or Services; (2) the computer or other device type you use to access or use our Sites or Services, the type of browser on the device, the browser’s settings, and the device’s operating system, software, and hardware; and (3) your mobile device’s unique mobile platform advertising identifier, if you access any of our Sites or Services from a mobile device.

If you visit or access any of our Sites, we also collect personal information from or about you regarding your activity on our Sites. This data includes information such as: the date and time of your visit to the Sites; the number of times you visit our Sites; the areas, pages, features, and applications of or on our Sites you visit or use; the amount of time you spend viewing or using the Sites or particular areas of them; emails that you open, forward or click-through to our Sites; and other websites you may visit from our Sites.

We may also collect personal information associated with feedback and correspondence from or with you, such as information you provide when you request information from us or otherwise correspond with us, including our Sites or via social networking sites or services.

Combining Information

We may take personal information we collect from or about you directly and combine that with other information, including personal information we obtain about from third party sources or that we automatically collect about through our Sites or Services.

HOW WE USE PERSONAL INFORMATION WE COLLECT

We use personal information that we collect from or about you to:

  • Deliver our Services to you.
  • Meet and enforce legal requirements, including ones pertaining to the determination of your eligibility to invest, identity verification, and “Know Your Customer” protocols.
  • Protect against, investigate, and deter fraudulent, unauthorized, and illegal activity.
  • Personalize your experience on our Sites or when engaging with us.
  • Provide advertising, including targeted advertising, in order to promote our Services.
  • Perform analytics about your access and use of our Sites or Services and advertisements.
  • On a de-identified, aggregated basis, analyze how you use the Services to help us understand traffic patterns and know if there are problems with the Services or areas in which we can improve.
  • Communicate with you, such as through email or text messages, in order to provide you with information and updates about us and our Services, and to respond to your comments and questions.

 

WITH WHOM WE SHARE PERSONAL INFORMATION WE COLLECT

Without your consent, we do not rent, sell, or share personal information with unrelated third parties, except: as necessary to complete a transaction or provide a service you have requested, or as provided in this Privacy Policy. 

Third Parties with Whom We Share Personal Information

Subject to the terms of this Privacy Policy and applicable law, we may share personal information we collect from or about you with the following categories of third parties:

  • Our Affiliates.
  • Government Agencies as required by laws and regulations.
  • Our partners. We utilize third party partners in some instances to assist us in delivering Services, such as our broker-dealer and escrow partners. We may share your personal information with them because they may require us or we may need to do so to facilitate the work they do for us.
  • Our service providers. We work with various third-party service providers, including database administrators, cloud computing services, advertising services, data analysts, identity verification services, accountants, auditors, and payment processors. We may provide your personal information to them to the extent required by law, required or needed to fulfill our obligations to you, or required or needed by such service provider to perform their service.

 

Other Instances When We Share Information with Third Parties

In addition to the third parties described above, we may transfer personal information we collect from or about you to a third party – 

  • in the event of a merger or acquisition. We may transfer personal information we collect from or about you to a third party if it acquires us or any of our assets or merges with us. Should such an acquisition or merger occur, we will use reasonable efforts to try to require the transferee to use personal information we have collected in a manner consistent with this Privacy Policy; or,
  • to meet legal obligations or for protection. We may also transfer your personal information to a third party when required by law or to respond to legal process or as necessary to protect our customers, lives, the security of our Services, or our rights or property. 

 

* * *

The manner in which partners, service providers, and other third parties with whom we share or disclose your information is governed by the policies of those third parties, and we shall have no liability or responsibility for their privacy practices or other actions. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in that case, we will only share information that is directly related to the applicable service(s).

Aggregated / De-identified information

Collected personal information may be aggregated and/or de-identified (we remove any details that identify you personally). We may share this aggregated and/or de-identified information with third party providers to help deliver products, services and content that are better tailored to the Users of our Sites or Services and for our own business purposes where permissible under applicable law.

HOW WE SAFEGUARD PERSONAL INFORMATION WE COLLECT

Your account with us is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser, including by signing off after you have finished accessing your account.

We are committed to safeguarding the confidentiality of your information but cannot guarantee the security of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we (1) encrypt any information we store, (2) transmit information via https and (3) limit access to this information to (a) authorized employees and contractors who need to know that information in order to operate, develop and/or improve our Sites or Services and (b) third parties that must receive that information in order to facilitate provision of our Services. 

Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. Unauthorized entry or use, hardware or software failure, or other factors may compromise the security of User information at any time. If you believe your information may not be secure for any reason, please contact us immediately at security@currant.co.

 

YOUR CHOICES REGARDING PERSONAL INFORMATION

You have several choices regarding the use of personal information we collect about or from you.

Changing or Deleting Your Personal Data

A User of our Sites or Services may review, update, correct or delete personal information furnished by the User by contacting us at security@currant.co or, in certain cases, by accessing their User account. For your protection, we may only share and update the personal information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you completely and permanently delete all of your personal information, then your User account will be deactivated. If you wish to cancel your account, you may do so by emailing us at security@currant.co, and any personal information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law, subject to our data retention policy.

Data Retention

We retain personal information we receive for as long as you use any of our Services or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements, and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Download or Access Personal Information

You can ask us for a copy of your personal information, including a copy in machine readable form, by emailing us at security@currant.co

Opting Out of Email Communications

We may use some of the information we collect for marketing purposes, including to send you promotional communications about new features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at security@currant.co to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this Privacy Policy.

OUR USE OF TRACKING TECHNOLOGIES

We may use cookies, pixel tags, or other technologies on our Sites or as part of our Services, including to collect information automatically or passively. 

A “cookie” is a small amount of data, often including an anonymous unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Sites and use them to recognize you when you return to our Sites. Cookies must be enabled on your web browser if you wish to access certain personalized features of our Sites or Services. By using any of our Sites or Services, you consent to our use of cookies.

You might be able to set your browser so that it does not accept cookies. The following website may have information useful if you wish to change your browser’s settings so it does not accept cookies: https://www.allaboutcookies.org/manage-cookies/. Unless you have adjusted your browser settings to refuse cookies, our system will send cookies as soon as you access our Sites or Services. Again, by using our Sites or Services, you consent to our use of cookies.

We may also use so-called “pixel tags”– small graphic images– to tell us what parts of our Sites have been visited or to measure the effectiveness of searches customers perform on our Sites. Pixel tags are sometimes referred to as “web beacons.” Pixel tags also enable us to send email messages in a format customers can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our Users.

ADDITIONAL PRIVACY RELATED INFORMATION

Links to Third-Party Websites

We may provide links to third-party websites on our Sites or in our communications or other materials exchanged with you. We have no control over those websites, and they may be subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, those third-party websites. By using any of our Sites or Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third-party websites.

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and other online services you visit. We do not alter our practices when we receive a “Do Not Track” signal from your browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

If you access or use any of our Sites or Services from a mobile device, we may collect mobile advertising identifiers to provide certain Services or facilitate use of our Sites. Users may be able to opt out of interest-based advertisements through the most recent applicable settings features of their mobile devices. These opportunities are subject to the offerings made available by the third-party operating system providers and subject to their privacy policies, if any, and not any our offerings or our Privacy Policy. Please note that opting out of mobile advertising identifier collection may prevent certain Services from functioning properly.

California Residents

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at security@currant.co.  Please include the statement “Your California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. For more information, please see Appendix – CCPA Disclosures. 

Users Outside the United States

Currant LLC is based in the United States. Our Sites and Services are controlled and operated by Currant LLC from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Sites or Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

Children

We do not use our Sites or Services to knowingly solicit data from, or market to, children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at security@currant.co.  We will delete such information from our files within a reasonable time.

CONTACT US

Please contact security@currant.co if you have questions about this Privacy Policy, your personal information, or our Sites or Services.

 

Appendix – CCPA Disclosures

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name NO
B. Personal information categories listed in the California Customer Records statute Name, contact information, education, employment, employment history, and financial information NO
C. Protected classification characteristics under California or federal law Gender and date of birth NO
D. Commercial information Transaction information, purchase history, financial details, and payment information NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements NO
G. Geolocation data Device location NO
H. Audio, electronic, visual, thermal, olfactory, or similar information Images and audio, video or call recordings created in connection with our business activities NO
I. Professional or employment-related information Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us NO
J. Education Information Student records and directory information NO
K. Inferences drawn from other personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics NO
L. Sensitive Personal Information NO

 

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Currant collects and shares your personal information through:

  • Targeting cookies/Marketing cookies
  • Social media cookies
  • Beacons/Pixels/Tags

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at legal@currant.co, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

Currant has not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your rights with respect to your personal data

  1. Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

  1. Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information we collected about you.

 

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

  1. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

  1. Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer’s sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
  • You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

 

To exercise these rights, you can contact us by email at legal@currant.co, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.