Privacy Policy

Introduction

This Privacy Policy outlines Rembrandt Investments LLC, doing business as Rembrandt Investments,  (“we”, “our” or “the Company“) practices with respect to information collected from users who access our website (the “Site“), communicate with us in any other way, including registration and using our services (collectively: “Users“).

Our Site allows its Users, which are small medium businesses, to connect with funding providers. The connection is made based on an application submitted by a User (“Application(s)“) and is processed by our proprietary algorithm.

We encourage Users to carefully read the Privacy Policy and use it to make informed decisions. In this Privacy Policy you can read about:

What type of information do we collect.
Legal basis for processing.
How we use and with whom we share the information.
User rights.
For how long we retain the information.
Cookies.
How we safeguard the information.
How to contact us.

We collect two types of data and information from Users who access our Site.

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your access to the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. browser type, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. clicks, actions, etc.).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). When you submit an Application or fill out a form on our Site, such information may include:

Contact information: basic contact information will normally include your name and email address.

Application information: If you choose to submit an Application, you would be required to provide additional information (in addition to the Contact information) in order to complete such application – this information may include your personal physical address, phone number, date of birth, bankruptcy history, credit score, 4 last digits of SSN, copy of state ID or driver’s license.

We may use a third party service to enrich your application profile with additional, publicly available information. We ensure that our third party service providers act in accordance with all applicable laws and are providing such information lawfully and legally.
If you choose to use the Finicity service offered on our Site, then we may also receive bank statements.

Device Information: We may also collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

We may also receive information regarding your Application from our third party funding providers, such as the status of your Application, the amount and terms of any funding provided to you and additional information associated with the funding. ‍If we associate Non-personal Information with Personal Information, we will treat such information as Personal Information. ‍

How is the information used? With whom do we share the information?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.‍ We may use the information for the following:

Communicating with you – If you have contacted us, for any reason, we will use your information in order to further communicate with you.
Verifying and authenticating the registration information provided by you.
Sharing your Application with our trusted third party providers, in order to provide you with applicable offers and solutions.
Calculating our services fees from our third party providers.
Conducting statistical and analytical purposes, intended to improve the Site and our services.
Inform you of additional products, services or promotions (unless you have opted out of receiving such communications).

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes:

Providing you with our service, including providing a personalized display of our Site;
Storing and processing such information on our behalf;
Performing research, technical diagnostics or analytics;

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

In any case we will conclude that disclosure of Personal Information is necessary, we will only disclose that portion of the Personal Information that is required in order to satisfy the basis for disclosure. We will share the Personal Information under appropriate safeguards.

Communications

We may send you email, text and social media messages (including but not limited to Facebook or Twitter), or contact you via telephone calls or direct mail.

By accepting the Terms and Conditions for the Site and the services (including the terms of this Privacy Policy which are incorporated therein) or using the Site or services, you affirmatively consent to receive such commercial messages on an on-going basis throughout your use of the Site or Services. You can remove your personal information from our mailing list and stop receiving future communication from us by following the unsubscribe link located at the bottom of each communication or by emailing us at [email protected]. You will also be given the opportunity to unsubscribe from commercial messages in any such email we send. Please note that we reserve the right to send you service related communications, including service announcements and administrative messages, relating to your interactions on this Site or services, without offering you the opportunity to opt out of receiving them unless you withdraw any pending Application and cease using the Site or service. Please note that you may still receive information from third parties to whom we may have disclosed your Personal Information prior to your opt-out. If you no longer wish to receive information from such third party, please contact them directly.

Retention

We will retain your Personal Information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We use cookies and other technologies in our related services, including when you visit our site or access our Services.4A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. Our website uses cookies in order to provide you with Services, identify you for repeat visits, (for example to allow us to store your preferences for the next sign-in), and monitor and analyze our web access. You may remove the cookies by following the instructions of your device preferences; You can find more information about cookies at www.allaboutcookies.org; however, if you choose to disable cookies, some features of our Service may not operate properly and your online experience may be limited.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including

any of the third parties which we may disclose information as set forth in this Privacy Policy.

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied, or otherwise, that we will prevent such access.

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the5event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

The Site is intended to the use of individuals over the age of 18. In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If have any reason to believe that a child under 18 has shared any information with us, please contact us at [email protected].

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the “Last modified” section. Your continued use of the Site or services, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

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