Privacy Policy of Poolit

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FACTS

WHAT DOES POOLIT DO WITH YOUR PERSONAL INFORMATION?WHAT DOES POOLIT DO WITH YOUR PERSONAL INFORMATION?

Why?

Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.

What?

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

• Social Security number and account balances


• Name, address, and income


• Account transactions and checking account information

When you are no longer our customer, we continue to share your information as described in this notice.

How?

All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Poolit chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information

Does Poolit share?

Can you limit this sharing?

For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus

Yes

No

For our marketing purposes — to offer our products and services to you

Yes

No

For joint marketing with other financial companies

Yes

No

For our affiliates’ everyday business purposes — information about your transactions and experiences

Yes

No

For our affiliates’ everyday business purposes — information about your creditworthiness

No

We don't share

For our affiliates to market to you

Yes

No

For nonaffiliates to market to you

No

We don't share

Who we are?

Who is providing this Privacy Policy?

This privacy notice is provided by Poolit, Inc.

What we do?

How does Poolit protect my personal information?

To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

How does Poolit collect my personal information?

We collect your personal information, for example, when you:

• Open an account or provide account information


• Make deposits or withdrawals from your account


• Sync external accounts to your Poolit account

We also collect your personal information from other companies.

Why can’t I limit all sharing?

Federal law gives you the right to limit only: • Sharing for affiliates’ everyday business purposes — information about your creditworthiness
 • Affiliates from using your information to market to you
 • Sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. 
 See below for more information on your rights under state law.

Definitions

Affiliates

Companies related by common ownership or control. They can be financial and nonfinancial companies.

Nonaffiliates

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

• Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf and direct marketing companies.

Joint Marketing

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

• Our joint marketing partners include financial services companies.

Poolit Privacy Policy

Our Commitment to Privacy

At Poolit, we want you to understand how and why we use, store, secure and otherwise process your Personal Data. This policy also aims to explain the rights you have with respect to your Personal Data, which may vary depending on where you are located. 

For example, certain privacy rights may apply to the extent that EU, UK, Hong Kong, Singapore, U.S. or other privacy or data protection legislation applies to our processing of your Personal Data, or to the extent you are located in those jurisdictions.  

As such, “Personal Data” has the meaning given to it in the relevant data protection legislation and includes any data or information relating to an identifiable individual (such as name, address, date of birth or economic information), or which may identify an individual from other information to which an organization is likely to have access.

By virtue of interacting with the Poolit platform that is made available through our mobile application and via https://www.thepoolit.com or any of its subdomains (the “Platform”), or by becoming a Poolit Fund investor, you will provide the Platform with Personal Data.  The Platform is part of your agreement with Poolit Fund Management, LLC, as well as with any fund vehicle (each, a “Fund”) you may choose to invest in via the Platform.

Types of Data Collected

In connection with Poolit’s business activities, we collect various types of Personal Data, including, among other things:

  • Personal Identifiers - such as your name, postal address, tax ID, passport number, email address, account name, social security number, driver’s license number, mail address, phone number, or other similar identifiers. 


  • Online Identifiers – including operating system, browser name and version, and/or personal IP addresses.


  • Device Information – including type of device, device ID, Universally Unique Identifier, advertising identifiers (“IDFA” or “AdID”), operating system and version, wireless carrier, and network type.


  • Commercial Information – including tax information, bank account details, credit card number, money transfers including communications on bank transfers, assets, investor profile, credit history, debts and expenses. 


  • Internet & Network Activity Information – including browsing history, search history, preferences, authentication data, security questions, click-stream data, public social networking posts, login data, transaction (including, but not limited to, linking your external bank account to the Platform, depositing funds onto the Platform, or purchasing an investment), and other data collected via web beacons, pixel tags, embedded links, cookies, and other similar tracking techniques.


  • Professional Information – including your employment history, employer’s name, and remuneration.


  • Account & Login Credentials – those used to connect to the Platform as well as other institutions such as private banks or family offices of whom you may be a client.

Methods of Collection

1. Directly from You (e.g., when you voluntarily submit information to the Platform, or send us an email or other written correspondence):

  • From the forms and any associated documentation that you complete when subscribing for an interest in a Fund.
  • When you undergo certain verification checks and submit identity information such as your identity card or passport.
  • When you provide it to us via email or other correspondence.
  • When you make transactions with respect to the Platform.
  • When you purchase securities via the Platform and/or tell us where to send money.