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Nova is committed to the protection of your privacy. We understand that keeping your information secure and confidential is critical to earning and keeping your trust. This Privacy Policy describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information.
Secfi, Inc. and/or its affiliates (“Secfi”, “we”, or “us”) offers education tools, shareholder and options exercise financing solutions, financial planning, and wealth management, and may offer additional services in the future (the “Services”). We refer to those who establish an account with us (“Account”) as “Users”. We refer to those who visit our website without logging into an Account or using our service offerings as “Visitors”. We refer to those who enroll in our Exercise Financing & Loans or Liquidity Financing & Loans as “Customers”” and those who enter into a financial planning and/or investment advisory agreement as “Clients.” This Privacy Policy governs your use of our services, along with our Terms of Service into which this Privacy Policy is incorporated by reference.
1. How to use this privacy policy
This Privacy Policy explains how Secfi gathers and uses your Personal Information in the context of each of Secfi’s service offerings. All of Secfi’s services are made available through Secfi’s website, www.Secfi.com (“Site”). In particular, we describe how your Personal Information is shared and/or disclosed, and how we collect and use other non-Personal Information. We also describe how we address other privacy and security matters – such as our overall security practices, deletion of your Personal Information upon request, and opting-out of marketing communications. Lastly, we describe methods for contacting Secfi if you have privacy or security questions, comments or feedback.
2. Information collection
The types of information we collect depend on whether you are a current or former User, Visitor, Customer and/or Client. We collect Personal Information from you when you voluntarily provide it to us. Examples of instances when we collect Personal Information include:
when you answer questions on the Site to determine what kind of services we might recommend if you were to become a Customer and/or a Client;
- when you provide information about the company you have equity in;
- when you register to open an account;
- when you contact our client service organization with questions or;
- when you become a Customer or Client;
- Wherever Secfi collects Personal Information, we endeavor to provide a link to this Privacy Policy.
2.1. Information we collect from users
We collect personal information such as name, address, telephone number and other optional information you may provide, such as your age, financial assets, which may include the options and shares you hold, income in
2.2. Information we collect from Customers and Clients
If you choose to become a Customer and/or a Client, in addition to the information we collect from you as a User, described above, we will ask you for certain additional Personal Information, including but are not limited to:
your and your dependents’ full legal name, contact information, birth date, Social Security Number, and citizenship;
your approximate net worth, and other regulatory disclosures that may be necessary and required by federal and certain statutory laws.
2.3. Information regarding children
Due to the nature of our business, Services and benefits are not marketed to minors. Secfi does not knowingly solicit Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information to Secfi. If we learn that we have collected Personal Information directly from a minor, we will delete such information from our files. If a parent or guardian becomes aware that his or her child under the age of 18 has directly provided us with Personal Information without his or her consent, he or she should contact us at privacy@secfi.com and we will delete such information from our files.
2.4. Other ways we collect information
Other means by which we collect Personal Information include the following:
- Anonymized or aggregated Information: Secfi’s Site automatically records certain anonymized or aggregated information about your use or evaluation of the Services. Anonymized or aggregated information is used for a variety of functions, including the measurement of Users’ interest in and use of various portions or features of the Site. Anonymized or aggregated information is not Personal Information, and we may use and distribute such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Cookies and Pixels: Similar to other technology platforms and services, Secfi uses cookies, a small piece of computer code that enables our Web servers to “identify” Users, each time an individual initiates a session on our websites. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your own hard drive at any time. However, cookies may be necessary to provide access to much of the content and many of the features of the Site. For more information on how we use cookies, please see our Cookie Policy.
- Pixel Tags: Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Site. A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.
- Site Activity: Secfi may also use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on our Site. For more information on these third parties, including how to opt out from certain data collection, please visit the site below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Site or our Services. For Google Analytics, please visit www.google.com/analytics
- “Do Not Track” Technology: We do not collect personal information about your online activities over time and across different web sites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different web sites or online services.
2.5 Information we collect from other sources
We obtain information about you from other sources as described below.
- Vendors and Business Partners: We collect information about you from companies that we do business with, such as name, contact data, inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification and fraud prevention partners.
- Financial Account Linking: Secfi offers account linking and aggregation services through Plaid Inc. (“Plaid”). By utilizing these services, you acknowledge and agree that the terms of Plaid’s Privacy Policy (currently located at https://plaid.com/legal/#end-user-privacy-policy) will govern Plaid’s use of such information, and you consent to Plaid’s Privacy Policy. Further, you expressly grant Plaid the right, power, and authority to access and transmit your information as reasonably necessary for Plaid to provide its services.
- Publicly Available Data: includes contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.
3. How we use information
We use your Personal Information to provide our Service, to help you evaluate our Service, offer you new products or services, and enhance our Service. We may also use your Personal Information in a number of ways, including research, internal analysis, and analytics.
Secfi stores, processes, and maintains Personal Information related to you in order to provide client support, offer new products or services and provide our Services to Customers and Clients in accordance with the rules of regulatory bodies such as the Securities and Exchange Commission (the “SEC”) and Financial Industry Regulatory Authority, Inc. (“FINRA”). As a User, you may choose not to provide such information to us, but if you choose not to provide such information, you will not be able to become a Customer or Client.
We will not sell, rent, or trade your Personal Information (whether you are a current or former Customer or Client) to any nonaffiliated third parties except as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities, suspected fraud, front running or scalping, situations involving potential threats to the physical safety of any person, or violations of our Terms of Service. To the extent permitted by law, we may also disclose Personal Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such Personal Information is necessary or advisable, for example, to protect the rights, property, or safety of Secfi or others.
Secfi may share your Personal Information among affiliated Secfi entities in connection with the marketing and/or provision of Services to Users, Customers, and Clients.
There are certain circumstances in which we may share your Personal Information with non-affiliated third-party services providers, including to perform certain business and technology related functions and to support provision of the Services.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be transferred as part of such a transaction, as permitted by law and/or contract.
We will not share your Personal Information with non-affiliated third parties that may use such information to market to you without obtaining your opt-in consent. For example, we may offer you a product opportunity that requires us to share your Personal Information with non-affiliated third parties that may use such information to market to you. We will obtain your opt-in consent to such sharing of your Personal Information when we present you with the terms of such offer. If you have opted-in for this kind of sharing, then you may: (i) choose to opt-out of such sharing by contacting us at privacy@secfi.com; or (ii) request certain information regarding our disclosure of such Personal Information to such non-affiliated third parties by contacting us at privacy@secfi.com. If you would like to opt-out of our sharing of your Personal Information with its affiliates so that such affiliates can use your Personal Information to market to you, please contact us at privacy@secfi.com.
4. Security
Secfi takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, and unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error free therefore, we cannot ensure or warrant the security of any information you transmit to us. You can find more information on how we are safeguarding your data here.
5. Important information
By using and continuing to use the Site and/or Services, or otherwise providing us with personal information (such as an email address) you agree to the terms and conditions of this privacy policy and any updates thereto. This policy may change from time to time. This is our entire and exclusive privacy policy and it supersedes any earlier version.