Effective: March 15, 2018
Cyndx is committed to the protection of the Personal Data that it collects and processes to conduct its businesses. To meet this obligation, Cyndx has developed and implemented sound physical, technical, and administrative procedures reasonably designed to prevent the loss, misuse, unauthorized access, disclosure, alteration, and / or destruction of the Personal Data it collects and maintains.
Cyndx uses industry-standard encryption and a comprehensive authentication protocol to protect Personal Data while in transit through the Internet and at rest in Cyndx databases.
Collection of Personal Data
The Cyndx database is comprised of data that is obtained from multiple sources. Cyndx pays subscription fees to certain third party data providers that maintain a large body of information that has been collected from public sources. Cyndx obtains information that is publicly available through websites. Cyndx Subscribers may enter Personal Data into the Cyndx database when soliciting interest in a particular financial transaction. Companies may enter Personal Data into the Cyndx database to record the identity of holders of their securities or recipients of an incentive award or stock option.
Users assigned a password to access the protected areas of the Site are required to provide certain personal data including name and email address. Investors may provide Personal Data to complete a profile sought by Subscribers offering an investment opportunity. Cyndx collects Personal Data when Subscribers upload documents to the Site. Subscribers upload electronic information about securities offerings and the Subscriber’s business history and future prospects.
Upon accessing the Site, Cyndx collects the User’s IP address, the location of the User’s Internet Service Provider, the type and version of Internet browser used, and the website from which the User accessed the Site. Cyndx also collects information regarding a User’s Site usage, such as the time spent on a page and the number of pages viewed.
Cyndx collects this website data to monitor usage of the Site, the number of visitors to the Site and the number of Subscribers and Investors that have been assigned passwords. Cyndx may extract and use website data for internal purposes, in order to analyze the performance of the Site and its applications.
The statistics generated in this manner contain no Personal Data and cannot be used to gather any information about individual visitors to the site.
Cyndx also uses action tags. An action tag is a small piece of code that is placed on a webpage or in an email in order to track the pages viewed or the messages opened, the date and time when a User visits the Site, the Site from which the User came, the type of browser used, and the domain name and address of the User’s Internet Service Provider. Action tags allow Cyndx to better understand how Users and visitors use the Site or browse through the Site’s pages, to improve access to and navigation through the Site. Action tags cannot be removed or deleted by Users, because they are part of the programming of the Cyndx Site.
Cyndx monitors log file information. Log file information is automatically reported by a User’s browser each time a User access a web page. Cyndx servers record certain information when a User accesses the Site. These server logs may include information such as a User’s web request, IP address, browser type, referring/exit pages, operating system, date/time stamp, the files viewed on our site (e.g., HTML pages, graphics, etc.) and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information.
Cyndx collects Personal Data through e-mail, text and other electronic messages between Cyndx and Users, on the Site or otherwise.
How Personal Data Is Used
Cyndx uses Personal Data to provide services to Subscribers and Investors. A Subscriber may use Personal Data to contact an Investor from a curated list to ascertain whether such Investor has an interest in a prospective transaction, or to record an Investor’s ownership of securities or option to purchase a Subscriber’s securities.
Cyndx may use Personal Data to monitor how Users access the site, and to track or improve user experience. Cyndx may use Personal Data to correspond with a Subscriber or Investor directly, in order to resolve a conflict or respond to a question or complaint.
Sharing Personal Data
Cyndx does not share Personal Data publicly. Investors seeking information about Subscribers are required to treat such information confidentially
Cyndx shares Personal Data with its Subscribers. Personal Data is in the Cyndx database because the respective data subject provided Cyndx with the consent to process the Personal Data or the data subject has provided a third party with consent to process the Personal Data and such third party shared the Personal Data with Cyndx.
The Personal Data of an Investor remains in the database regardless of whether the Investor participated in a Subscriber’s offering. Such Personal Data is shared with the next Subscriber that bears characteristics similar to the Investor’s preferred investment opportunities.
Cyndx shares Personal Data with its technicians or third party consultants or professionals that have been engaged by Cyndx to enhance or repair the product offerings provided to Subscribers and Investors.
Cyndx shares Personal Data upon a request or demand of a federal, state, or municipal agency that exercises jurisdiction over Cyndx, or in response to a valid court order or subpoena.
Cyndx shares Personal Data in order carry out contractual obligations and enforce rights arising from any contracts entered into between Subscribers and Investors and Cyndx, including for billing and collection of applicable fees.
Cyndx may share Personal Data to make queries to social networking and other sites, such as LinkedIn, for a variety of purposes, including, but not limited to, verifying Subscriber or Investor identity, and showing identifying you how a Subscriber or Investor is linked or connected to other Subscribers or Investors.
Cyndx may share Personal Data with its affiliates.
Cyndx does not rent, sell, or share Personal Data with third parties or nonaffiliated companies for their direct marketing purposes.
Viewing Personal Data
Users may view the Personal Data that Cyndx has collected on such User to ensure accuracy or evaluate a request to revoke the consent to process such Personal Data by contacting Cyndx Customer Support at email@example.com.
Requests to Delete Personal Data
Upon written request, Cyndx shall provide Users with an electronic copy of User’s Personal Data and will delete such Personal Data from the Cyndx database in the event that the User provides notice that he / she has withdrawn consent to Cyndx to process his / her Personal Data for its business purposes. In some instances, a User’s right of access to Personal Data may be limited to the extent that providing the User with an electronic copy may infringe upon another User’s privacy rights. In such instances, Cyndx will redact that portion of the Personal Data that infringes upon a third party’s data privacy rights before making such information available to the User that requested the review. Requests for access to this archived information are handled on a case-by-case basis, after Cyndx has verified the identity of the User making the request.
Personal Data Retention
Cyndx retains Personal Data until a User provides Cyndx with a directive to remove it.
Personal Data Breach Notification
Both the United States and the European Union regulatory schemes require that Cyndx provide Users with a notification in the event of a material breach of the Cyndx safeguards and a resulting loss or unauthorized access to Personal Data. Cyndx shall make this notification to Users electronically, via an electronic message within 72 hours of the discovery of such breach.
Links to Other Websites
From time to time, Cyndx may add links to third party websites to the Site. Cyndx is not responsible or liable in any way for the privacy practices or content of these linked sites.
Limitation of Liability
Cyndx exercises reasonable efforts to safeguard the security and confidentiality of Personal Data; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. To the extent permitted by law or regulation, Cyndx will not be liable for unauthorized disclosure of Personal Data that occurs through no fault of Cyndx including, but not limited to, errors in transmission, access to Subscriber’s or Investor’s Personal Data through Subscriber or Investor’s loss or misuse of an assigned password, or a User’s your failure to comply with his / her contractual security obligations.
California Privacy Rights
California Civil Code Section § 1798.83 permits Users of the Site that are California residents to request certain information regarding the disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org