Effective Date: November 2021

Welcome! This privacy policy (“Privacy Policy”) describes the types of personal information we collect from you and other people with whom we communicate and interact via our website http://percent.com (including both mobile and online versions) (the “Site”), including your use of interactive features, platforms, investor marketplace, widgets, plug-ins, applications, content, downloads and/or other online services that we own and control and that post a link to this Privacy Policy, as well as other online or offline channels, including via the telephone, paper, or in-person communications (collectively with the Site, the “Service”), which are made available by Cadence Group, Inc., (DBA Percent Technologies), and its subsidiaries, affiliates and/or delegates, including Cadence Group Platform, LLC, (DBA Percent Technologies Platform), Cadence Securities LLC, and Percent Securities, LLC (collectively, the “Percent Entities” and individually a “Percent Entity”, “we” “our” or “us”). This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not govern the data practices of third parties that may interact with our Service.

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Service’s Terms of Use, which governs your use of the Service. You utilize our Service pursuant to the disclosures provided in this Privacy Policy and as required in our Terms of Use, as described below. If you do not wish for us to utilize information as disclosed in this Privacy Policy, please do not provide us with any Personal Information and do not use this Service.

1. What Information Does the Service Collect?

   We only collect Personal Information that is adequate, relevant, and not excessive in relation to the purpose or purposes for which the information is collected or processed.

   For the purposes of this Privacy Policy, “Personal Information” means any information that reasonably can be used to identify you as an individual person. Personal information does not include publicly available information or information that has been anonymized, de-identified, or aggregated.

   1. Personal Information You Provide to Us

      The Service connects accredited investors with investment opportunities and efficiently communicates with investors, distributes investment documents and centralizes ongoing investor relations. To effectuate these investing opportunities, we may collect the following Personal Information about you that you choose to provide us when you use our Services:

      • Contact information. In connection with our Services, we may ask you to provide us with certain categories of contact and other personally identifiable information, such as your first and last name, phone number, email address, home address, social security number, and driver’s license, passport, or other government-issued identification numbers.
      • Financial and payment information. In connection with our Services, we may ask you to provide us with your financial account information, account statements, and related financial information, such as state of income tax, that is required or will assist us in providing Services or handling payments and transfers.
      • Account information. We require a username and password to create your account for our Services.
      • Business information. We may collect information about the company you work for, business contact information, your job title, and company financial information.
      • Demographic and other information. You may be required or provided the opportunity to provide us with certain other information about yourself, including your date of birth, state of driver’s license, state of voter registration, and your signature. We may also collect certain background information as part of our investor verification and due diligence process, including criminal history, residential history, and eviction history.
      • User Content. The Service may permit you to submit ideas, photographs, investment information, loan information, investing experience, company information video, audio recordings, computer graphics, pictures, data, information about your location, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”), such as on publicly available investment profiles.

      We may collect this information through various forms and in various places on the Service, including if you register for an account, post an investment opportunity, through “contact us” forms, or when you otherwise interact with the Service. If we combine any of the above information, we will treat the combined data as Personal Information under this Privacy Policy.

   2. Information Collected and Stored as You Access and Use the Service

      In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat it as Personal Information. This Usage Information may include:

      • your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier;
      • your Device functionality (including browser, operating system, hardware, mobile network information);
      • the areas within our Service that you visit and your activities there, including remembering you and your preferences;
      • your Device location;
      • your Device characteristics; and
      • certain other Device data, including the time of day, among other information. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Service, include, without limitation, cookies, web beacons, embedded scripts, browser fingerprinting, entity tags, UTM codes, and recognition technologies that make assumptions about users and devices (and subsequent technology and methods later developed).

      We may use Tracking Technologies for a variety of purposes, including:

      Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, improve security or allow you to make use of Service functionality.

      Performance‑Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, ads, products or services offered through the Service.

      Functionality–Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you use our Service or keeping track of your specified preferences.

      Targeting‑Related. We may use Tracking Technologies to deliver content, including ads relevant to your interests on our Service and third‑party services based on how you interact with our advertisements and/or content. This includes using Tracking Technologies to understand the usefulness to you of the content and ads that have been delivered to you.

      There may be other Tracking Technologies now and later devised and used by us in connection with the Service. Further, third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party websites or online services as well as across your Devices. We may not control those Tracking Technologies and we are not responsible for them. However, you may potentially encounter third-party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties.

   3. Location-Based Information

      Our Service may use location-based services in order to locate you so we may verify your location, deliver you relevant content and ads based on your location as well as to share your location with our vendors as part of the location-based services we offer. You may be able to change the settings on your Device to prevent it from providing us with such information. Unless you provide consent at or before the point of collection, this location data is collected anonymously in a form that does not personally identify you and is used by us and our partners and licensees to provide and improve location-based products and services. You should consider the risks involved in disclosing your location information to other people.

   4. Information Third Parties Provide About You

      We may, from time to time, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. Further, we may use third parties to collect details about you from financial institutions as part of our registration process and to determine an investor’s suitability to be an investor on the Service. To the extent we combine information we receive from those sources with Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us.

   5. Interactions with Third-Party Services

      The Service may include functionality that allows certain kinds of interactions between the Service and a third-party web site or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, we may provide third-party sites’ interfaces or links on the Service to facilitate your sending a communication from the Service. For example, we may use third parties to facilitate emails, tweets or Facebook postings. These third parties may retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Service.

   6. Do Not Track Disclosures

      Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.

2. Information You Provide About a Third Party

   You may send someone else a communication from the Service, such as sending an investment opportunity to a friend. If so, the information you provide (names, email addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Service, your contact information, name or username and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.

3. How Do We Use the Information Collected?

   We rely on one or more legal bases to process your Personal Information under applicable law. We may process Personal Information (i) as necessary to perform our contractual obligations to you; (ii) as necessary to pursue our legitimate interests; (iii) as necessary for our compliance with our legal obligation such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent, including to send you marketing email messages and other information that may be of interest to you.

   Legitimate business interests. We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others.

   We may use your Personal Information for the following legitimate business interests:

   • to determine an investor’s suitability to be an investor on the Service;
   • to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming events;
   • to process and track your investments and other transactions you enter into using the Service;
   • to provide liquidity to our investors;
   • to verify your identity, including your accounts on the Service;
   • manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;
   • manage and protect our information technology infrastructure;
   • to provide the Service, including the marketplace opportunities available on the Service;
   • to improve the Service, marketing endeavors or our Service offerings;
   • to customize your experience on the Service or to serve you specific content or ads that are relevant to you;
   • to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;
   • to contact you with regard to your use of the Service and, in our discretion, changes to the Service and/or Service’s policies;
   • to identify your product and Service preferences so that you can be informed of new or additional products, services and promotions;
   • to enable you to participate in a variety of the Service’s features;
   • to improve the overall experience at the Service;
   • where it is necessary to comply with our legal and regulatory obligations, such as compliance with anti-money laundering and FATCA/CRS requirements, and otherwise to screen transactions for fraud prevention, anti-money laundering purposes, and the prevention of crime and the reporting of appropriate tax-related information to tax authorities;
   • where it is necessary for the performance of our rights and obligations under the subscription agreement and/or the constitutional and operational documents of the offering;
   • to preform financial and regulatory accounting and reporting;
   • for quality, regulatory compliance, business analysis, training and related purposes, consistent with our legitimate interests, in the monitoring and recording of calls and other communications;
   • for the investigation and assertion of our legal rights; and
   • for internal business purposes

4. How and When Do We Share Information with Third Parties?

   We may share non-Personal Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers and data related to you and your activities with our vendors and service providers for our business purposes. We may share your Personal Information with Sponsors (as defined in the Terms of Use), borrowers, investors, banks, lenders, credit bureaus, agencies and payment processing service providers so they can assist with processing the investments and other transactions initiated from your Service account. If you are a California resident, you have the right to request additional information about this sharing, so please see Section (4)(f) below. In addition, we may share the information we have collected about you, including Personal Information, as described belowin this Privacy Policy. We may additionally disclose your information as follows:

   1. When You Request Information from or Provide Information to Third Parties. You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools, apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
   2. Third Parties Providing Services on our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Service, such as: (i) to assist us in Service operations; (ii) to manage a database of customer information; (iii) hosting the Service; (iv) designing and/or operating the Service’s features; (v) tracking the Service’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; (vii) process investments; and (viii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third-party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
   3. To Protect Our Rights. We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Service’s Terms of Use or other policies applicable to the Service, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Service or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers to identify users and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you.
   4. Affiliates and Business Transfer. Certain Percent Entities may share Personal Information among other Percent Entities in connection with rendering Services that you have requested. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

5. What About Information I Disclose Publicly or to Others?

   1. Public Information. We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that we do not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Service or what others do with information you share with them on the Service. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Service.
   2. Name and Likeness. We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Service, please review our Service’s Terms of Use.

6. Does Third-Party Content, Links to Third-Party Sites, and/or Third-Party Apps Appear on the Service?

   When you are on the Service you may be directed to other sites and apps that are operated and controlled by third parties that we do not control such as merchants who directly sell products and services to you. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Service onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third-party owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

7. What Should Parents Know About Children?

   We are committed to protecting children’s privacy in the interactive world. We are a general audience service that is available only to individuals who are at least18 years of age and the age of majority in their jurisdiction of residence, in accordance with our Terms and Conditions. As such, we do not anticipate collecting personal information from individuals under the age of 18, including any such collection that would require parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without parental consent. If you are under the age of eighteen (18) years of age, or otherwise under the age of majority in your jurisdiction of residence, you are not permitted to use the Service and should not send any information about yourself to us through the Service. In the event that we become aware that we have collected personal information from any child, we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at: support@percent.com.

8. Your Rights and Choices

   1. How Do I Change My Information and Communications Preferences?

      You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Service may allow you to review, correct or update Personal Information you have provided through the Service’s registration forms or otherwise by updating your Service account, and you may provide registration updates and changes by contacting us by email at: support@percent.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for our administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and Service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways:

      Postal Mail:
      Cadence Group, Inc., (DBA Percent Technologies)
      909 Third Ave #968 New York, NY 10150;Email:
      support@percent.com

   2. Your Privacy Rights

      In certain circumstances, depending on your residency, you may be entitled to the following data protection rights regarding your Personal Information:

      • Right to access. You may have the right to access (or “right to know”) your own Personal Information and receive information about how it is collected, used, disclosed, and/or sold, as may be applicable.
      • Right to rectification. You may have the right to request that Percent have inaccurate Personal Information rectified, blocked, erased, or destroyed if your complaint is upheld.
      • Right to delete. You may have the right to request that Percent delete your Personal Information in certain circumstances.
      • Right to opt-out of sales or otherwise restrict processing. You may have the right to request that Percent cease processing your Personal Information in certain circumstances.
      • Right to stop direct marketing. You may have the right to request that Percent cease or not begin direct marketing targeting of you.
      • Right to non-discrimination. You may have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

      Any request you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”) as permitted or required by applicable law. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the Personal Information. In order to verify you, you must provide us with your full name and email address. These rights are also subject to various exclusions and exceptions under applicable laws.

      Where the processing of your Personal Information is based on your previously provided consent, you have the right to withdraw your consent at any time. If you would like to exercise any of these rights, please submit a written request using the contact information provided at the end of this Privacy Policy.

      If you are a California resident, please review our California Privacy Addendum (Below) for further information regarding your privacy rights.

9. Social Security Numbers

   It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

10. Data Security and Retention

    We do not keep Personal Information for any longer than we need or are required to by law or regulation. To that end, we periodically review the Personal Information that we retain and erase or anonymize that information when it is no longer needed.

    We work hard to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk.

11. International Data Transfers

    We may transfer Personal Information, including sensitive data, to or from the United States or other countries from which the Personal Information was collected for storage, processing, and use by Percent. Those countries may have data protection rules that are different from those of your country. We will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this Privacy Policy. Personal Information transferred to another country may be subject to lawful access requests by courts, law enforcement agencies, or other government authorities in those other countries. If you are located in the Cayman Islands, we comply with any applicable laws to provide an adequate level of data protection to the U.S. Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use EU Standard Contractual Clauses with data recipients located outside the Cayman Islands.

    If you are located outside of the United States, please be aware that the Personal Information we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen. We will ensure application of the same standards of privacy protection as set out in this privacy policy regardless of the international transfer or processing of personal data. By providing us your Personal Information and/or using our website, you consent to such international transfers of personal data, as we deem appropriate, including transfers from the European Economic Area or the Cayman Islands to the U.S. and other countries, which the European Union has deemed not to provide “adequate” protections for Personal Information.

    Any transfer of Personal Data by us or our duly authorized Delegates outside of the jurisdiction in which it is collected shall be in accordance with any legal requirements, including those of the DPA and GDPR.

12. What about Changes to the Privacy Policy?

    We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

13. Dwolla

    You authorize Percent to collect and share with our payment provider Dwolla, Inc. your personal information including full name, date of birth, social security number, physical address, phone number, email address, registered business name, EIN and bank account information, and you are responsible for the accuracy and completeness of that data. This information will be used by Dwolla solely for the purposes of opening and supporting your Dwolla account.

    Dwolla’s Privacy Policy is available here.

    The following third parties that collect information from you on the Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:

    Party	Service	For More Information	Use of Tracking Technologies	Privacy Choices
    Google Analytics	Analytics	http://www.google.com/analytics/learn/privacy.html	Yes	https://tools.google.com/dlpage/gaoptout/

    PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate. Please contact the relevant third parties regarding their privacy and data security policies and practices.

14. Complaints

    We take very seriously any complaints we receive about our use of Personal Information. Questions, comments, requests, or complaints regarding this Privacy Notice, or wish to discuss your data protection rights with us, please contact using the information below.

15. Contact Us

    To exercise any of your rights or if you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us using the following information:

    Email:
    support@percent.comAddress:
    Cadence Group, Inc., (DBA Percent Technologies)
    909 Third Ave #968 New York, NY 10150;

Copyright © 2024 Percent Technologies. All rights reserved.