About this policy
Issuance, Inc. ("Issuance," "we," or "us") provides capital-raising technology. This policy describes our personal information practices for issuance.com, invest.issuance.com, and related investment interfaces, accounts, and issuer services that present or link to this policy (the "Services"). It covers visitors, business contacts, investors, issuers, and their representatives.
Issuers and their engaged broker-dealers use information to review investors and administer offerings under their own arrangements. We provide the technology that supports those activities and also process information to operate our business. Their independent practices and those of other financial providers are subject to their own notices and legal obligations.
Our Terms of Service describe use of the Services. Separate transaction notices and consents may also apply. Reg CF services provided by Jumpstart Micro, Inc. d.b.a. Issuance Express have separate terms and privacy notices. This policy does not replace them or provide consent for practices requiring separate consent.
Information you provide
Information collected depends on the service, offering, and interactions involved. It can include:
- Contact and account details: name, email, phone number, address, account identifiers, login information, preferences, and correspondence.
- Identity information: date of birth, Social Security or other tax identification number, government ID details and images, photographs or a selfie submitted for verification, and verification results.
- Eligibility and financial information: income, net worth, accredited-investor status, tax certifications, and supporting documents or professional attestations required for an offering.
- Transactions: investment selections and amounts, payment and bank information, transaction status, signatures, agreements, and related records. An authorized bank connection may provide account or balance information within the requested permissions.
- Business information: organization and representative details, formation and ownership information, tax identifiers, offering documents, and information submitted for onboarding or support.
- Inquiries and communications: newsletter subscriptions, questions, demo or partnership inquiries, form responses, and documents you send us.
Some information is collected directly by a verification or payment provider and shared with the platform. If you provide another person's information, you must have authority to do so and provide any required notice.
Information collected automatically
Our systems and integrated providers collect technical and activity information, including IP address, browser and device information, approximate location derived from network information, referring pages, URLs, advertising and browser identifiers, pages viewed, errors, and interactions with account or investment steps.
Cookies, local storage, pixels, scripts, and similar technologies support sign-in, preferences, forms, security, analytics, and advertising measurement. Campaign or referral identifiers can pass from an issuer's page into the investment interface. Activity may be associated with your account when you sign in or provide identifying information.
The public website loads Google Analytics and a Clearbit tag for traffic measurement and visitor analytics. Investment interfaces may use additional configured tools. Where enabled, usage analytics can record browsing sessions and interactions to identify errors and improve usability. Providers and collection depend on the page and features used; some requests occur when a page loads.
Information from other sources
We receive information from issuers, their authorized broker-dealers and representatives, identity providers, payment providers, and other participants in a transaction. This includes screening results, review decisions, transaction confirmations, and information needed to resolve discrepancies.
Accreditation workflows can receive information from a professional identified for verification, including their name, contact information, license details, attestation, and signature. A supported third-party sign-in service shares information needed to authenticate you. Public records and business information may support verification and fraud prevention. We may combine these sources with existing account or transaction records.
How we use information
We use information to provide accounts and software, respond to inquiries, onboard customers, deliver requested communications, and support investment operations. This includes collecting documents, initiating verification checks, presenting results for review, generating agreements, and facilitating payment and transaction records.
The issuer or its engaged broker-dealer, as applicable, reviews AML/KYC and eligibility information and makes the relevant decisions under the offering's arrangements. Our processing supports those decisions; our software can perform automated checks and retain the associated information and results.
We also use information to protect accounts, prevent fraud, diagnose problems, improve the Services, measure usage and campaigns, support marketing, manage preferences, meet applicable obligations, maintain records, resolve disputes, and enforce agreements. Marketing choices do not stop processing needed for account security, an authorized transaction, or a legal obligation.
Verification, payments, and service providers
The Services disclose information to providers according to the features and arrangements involved:
- Identity and compliance: Trulioo receives identity and business information in supported verification workflows. These may collect ID images and a selfie; the platform can receive and retain documents and results. Trulioo's Services Privacy Policy describes its practices. North Capital receives identity, financial, and transaction information where its compliance or financial-service integrations are used.
- Payments and financial services: Stripe processes supported payments and bank connections, receiving payment, billing, transaction, and related technical information. Selected banking, escrow, or custody providers receive information needed for their role in a transaction.
- Accounts and operations: Google Firebase supports authentication, and Google services support address completion. Cloud, hosting, storage, security, diagnostics, document, electronic-signature, email, SMS, and workflow providers process information needed for those functions.
- Website communications and protection: Mailchimp receives your email when you submit a newsletter subscription. Website hosting and anti-abuse providers, including Google reCAPTCHA on the contact form, process device, network, and verification information to help prevent automated or abusive submissions.
Not every provider is used for every offering. Providers may also have independent legal duties and privacy notices.
Issuers, broker-dealers, and other recipients
The issuer and any authorized broker-dealer receive information needed to review and administer the investment. Depending on their role, this includes contact and identity information, verification and accreditation documents or results, financial eligibility details, tax information, agreements, and transaction records. Other authorized participants, such as transfer agents, custodians, and professional advisers, may receive records needed for their services.
Issuer-connected customer relationship management, communications, and analytics services may receive contact, eligibility, and investment information. An issuer or broker-dealer may retain and use its own records under its notices and legal duties independently of your Issuance account.
Affiliates and personnel supporting the Services may process information for technology, administration, and support. We may also disclose information to advisers, regulators, law enforcement, courts, or others as needed to comply with law, protect rights and security, or resolve a dispute.
Information may be disclosed in a proposed or completed merger, acquisition, financing, reorganization, or transfer of the relevant business, subject to applicable law, or at your direction or with a separate authorization.
Analytics and advertising
Configured investment interfaces and issuer campaigns may use Google, Meta, and other advertising or social-platform tags. They can receive device and page information, browser or account identifiers, referral details, and registration or investment events. Event data may include the offering, investment reference, quantity, and dollar value.
Some Google and Meta integrations transmit hashed email, phone, or name information for matching and measurement. Hashing changes its format; it does not make information anonymous. Providers may match it to information they already hold.
Where configured, Segment receives browser and server analytics events. Server events may include ordinary, unhashed contact or account information, investment activity, and campaign identifiers. Platform measurement and issuer-configured integrations can operate separately.
These activities may qualify as a sale, sharing, or targeted advertising under some privacy laws, depending on the information, relationship, and applicable law. The choices below explain how to make requests and use available controls.
Outside websites and content
Issuer websites, third-party sign-in, embedded videos, and other external content have their own privacy practices. Their providers can receive page, device, and network information when content loads, and additional information when you interact. Following a link to another service makes its notices relevant to your activity there.
If a feature allows you to publish content, that content may be visible to others. Do not post credentials, tax identifiers, identity documents, or information you want kept private.
Your choices and privacy requests
Update available account details through the platform or contact support. Use unsubscribe instructions in marketing emails and available text-message opt-out instructions to change those preferences. Necessary account, security, service, and transaction messages may continue.
Browser settings can block or delete cookies and restrict some tracking. Provider settings may offer additional advertising choices. Blocking storage can affect sign-in or other functions. Browser controls generally apply to that browser and do not automatically stop information sent from our servers or erase information already collected.
Depending on your location, the information, and applicable law, you may have rights to access, obtain a copy, correct, or delete information; object to or restrict processing; or opt out of certain sales, sharing, or targeted advertising. Rights and exceptions differ, including for particular financial information and legally required records.
Send requests to privacy@issuance.com. We may need to verify identity or an agent's authority. If a request concerns records controlled by an issuer or another provider, we may need to coordinate with or direct you to that party. We will address applicable requests and explain limitations as required by law. Do not send a Social Security number or ID image in your initial email.
Retention and security
We retain information according to its purpose, the service and transaction involved, applicable agreements, and legal, accounting, security, and dispute-resolution needs. Some identity, investment, agreement, and communications records must remain after an account closes or a transaction ends. Account closure does not necessarily delete all associated records, including records retained to support an issuer's or financial provider's obligations.
We use safeguards designed to protect personal information. No system or transmission method guarantees security. Protect your credentials and contact us promptly if you suspect unauthorized access.
Children, updates, and contact
The Services are intended for adults, and accounts require users to be at least 18. Contact us if you believe a child has provided personal information so we can review and address it.
Updates will identify their effective date. We will give additional notice or obtain consent when required by law. Posting a policy does not itself provide consent for practices that require it.
For privacy questions or requests, contact Issuance, Inc. at privacy@issuance.com. For account or technical support, contact support@issuance.com.