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PRIVACY POLICY

Our Commitment to Privacy

At GrowthFountain, our most important asset is our relationship with you. This new financial movement is predicated on the idea that as a community we can do more than we do alone. Title III of the JOBS Act enacted Regulation Crowdfunding (“Regulation CF”) to allow local and small businesses to reach out to capital never before available, while giving investors the ability to make both a financial and personal investment in a company.

This Privacy Policy answers some questions about what information we collect, what we do with it, and most importantly the safeguards we implement in order protect your confidential information. The policy also describes how gathering information allows us to provide every user with a better and more customized experience.

We encourage you to review this Privacy Policy in its entirety since any use of the sites or services offered by GrowthFountain will be governed by the practices and policies outlined in this Privacy Policy. PLEASE NOTE – By agreeing to this policy you expressly consent to our collection, storage, use, and disclosure of your personal information in the manner described in this Privacy Policy.

As used in this Privacy Policy, “GrowthFountain”, “we”, “us”, and/or "our" means GrowthFountain Capital LLC, a company registered as a funding portal with the Securities and Exchange Commission (“SEC”). Additionally, this Privacy Policy covers information that may be shared with our affiliates, joint marketers, regulatory agencies and other third parties. Further, unless stated otherwise, users should assume that information that you actively contribute to GrowthFountain might be viewed publicly, including through search engines.

Application of Our Policy

TThis Privacy Policy applies to information collected in connection with your access to, use of, or interaction with, the web site www.GrowthFountain.com and related domains, subdomains and observable web pages, including without limitation joint marketing websites that are hosted by GrowthFountain (collectively, the “Platform”). This Privacy Policy also applies to any information collected in connection with GrowthFountain providing you with any products or services related to the Platform or arising out of your participation in, or your indication of interest to participate in, any offer or sale of securities under Section 4(a)(6) of the Securities Act of 1933 in connection with Regulation CF (collectively, the “Services”); and information collected in connection with GrowthFountain’s performance of any identification procedures, security checks or regulatory compliance activities, including any analysis, tracking, correlating or aggregating of data derived from such activities (collectively, “Security Activities”).

This Privacy Policy applies to business operators and entrepreneurs seeking to raise capital through the Platform, to investors evaluating securities listed on the Platform, to individuals seeking information on crowdfunding and to all other users of the Platform or any of the Services (in each case, a "User"). With respect to each such User, this Privacy Policy covers GrowthFoutain’s treatment of personally identifiable information collected about such User that is gathered at any time (all such information collectively, "User Data").

Information We Collect, How We Get It, & How We Can Use It

Accessing certain areas of the Platform will require you to create an account and provide us with certain personal information. The information we gather enables us to process your requests, communicate with you, and improve both out Platform and our Services. When you interact with us through the Platform or our Services, we may collect User Data and other information from you, including without limitation (a) information collected during your registration, (b) information on your use of or interaction with the Platform, (c) information from any background check, Security Activities or similar compliance related activities, (d) information that is combined with or derived from your User Data, (e) transaction information, (f) information derived from any use of any products or services offered by third parties or joint marketers, (g) information that you voluntarily make public such as participation in any communication channels on the Platform, (h) information from your inquiries or participation in any surveys, (i) financial information including payment and banking information, (j) information on how you interact with advertising on the Platform, (h) IP address information, browser information and other information automatically collected by our server logs such as internet service provider, referring/exit pages, date/time stamp, and clickstream data. GrowthFountain may store such information itself or such information may be included in databases owned and maintained by GrowthFountain affiliates, agents or service providers.

  • Use of Cookies In operating this Platform, we may use a technology called "cookies." Cookies are small files that we transfer to your computer's hard drive to help analyze the Platform’s web page flow, customize our Services, measure promotional effectiveness, and promote trust and safety. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies. We recommend that you leave the cookies activated, however, because cookies enable you to take advantage of some of our Platform's features, and you may not be able to access certain areas of the Platform or certain Services if your cookies are not activated. This Privacy Policy does not cover the use of cookies by our affiliates or service providers since we do not have access or control over these cookies.

    We may also use or employ technologies similar to cookies to provide our Services and help collect data. You agree that we may use cookies and other similar technologies to allow us to collect information and, among other things, to store your preferences and settings; to enable you to sign-in; to speed access to portions of the Platform, to provide interest-based advertising; to combat fraud; and to analyze how our Services are performing.

  • Information Collection through Surveys & Feedback GrowthFountain may conduct research on a User’s demographics, interests and other identifying characteristics based on the User Data and other information provided to GrowthFountain. We may also collect information from surveys and other interactive campaigns designed to generate User feedback.

How We Use Your Data

GrowthFountain may use your User Data and other personally identifiable information collected through the Platform to help us improve the content and functionality of the Platform, to better understand our Users and to improve the Services. GrowthFountain may use this information to communicate with you regarding the Services; to tell you about services we believe will be of interest to you or to provide administrative communications that are reasonably necessary to the Service. GrowthFountain uses your User Data to comply with applicable law and to perform the activities of a funding portal.

In general, you agree that the following are permitted purposes for collecting information: (a) to understand your needs, (b) to keep improving the Platform and Service, (c) for internal record keeping, (d) to communicate with you regarding information which we think you may find interesting, (e) to contact you for market research purposes, (f) to customize the Platform according to your interests, (g) to comply with law and make assessments regarding the potential for fraud, abuse or violation of law, (h) to process payments and transactions, (i) to respond to your requests and (j) to customize the advertising and content you see.

When We Share Your Information

We may on occasion share your User Data. You agree that in order to provide the Platform and Services, we may employ third parties to perform tasks on our behalf and in such circumstances may need to share your User Data with them to provide products or services to you. For example, we use a third party escrow agent in connection with holding certain investor funds and in doing so we are required to exchange information that may identify you or your User Data. For other activities, such as reducing fraud and ensuring the identity of certain Users, we may also use third parties with whom we might share User Data in order to carry out our internal compliance policies and perform Security Activities. You agree that we may use the User Data to obtain additional information about you from third party sources or to verify your identity so we can properly process your requests and reduce fraud. By accessing our Platform and using our Services, you hereby consent that we may use your User Data for such purposes and for any third party services that you select, such as the use of a transfer agent to whom we would provide your User Data to allow them to provide the requested services. The following further describes the types of circumstances in which we may share your User Data and other information with certain third parties without further notice to you:

  • Securities Transaction Disclosure. We may share your User Data with counterparties or regulators in connection with our effecting a securities transaction as a registered funding portal. For example, we may share information with a third party transfer agent or escrow agent to allow them to provide services in connection with the transaction. Additionally, we share investor information with issuers upon completion of a transaction to ensure proper record keeping.
  • Disclosure to Service Providers or Consultants. GrowthFountain, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include maintaining databases, ID verification, escrow services, and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These companies are authorized to use your personal information only as necessary to provide these services to us.
  • Disclosure to Joint Marketers. GrowthFountain may enter into joint marketing agreements in which we may provide User Data to measure the effectiveness of the joint marketing efforts. Examples of such disclosure include reporting to any third-parties the number of individuals that signed up on the Platform based on a referral from such third-party.
  • Required Disclosures. GrowthFountain may disclose your User Data if required to do so by law or if we have the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of GrowthFountain, (iii) act in urgent circumstances to protect the personal safety of users of the Platform or the public against fraud or other harm, or (iv) protect against legal liability. We may release User Data when we believe in good faith that release is necessary to comply with the law or to enforce or apply our terms of use and other agreements. This includes exchanging information with other companies and organizations for fraud protection and risk reduction.
  • Business Transaction Disclosure. In the event of a corporate sale, merger, reorganization, dissolution or similar event for GrowthFountain, User Data may be part of the transferred assets and, to the extent reasonably practicable, you may be notified as to any choices you may have regarding your personal information that may be transferred.
  • Disclosure of Aggregated Data. GrowthFountain may aggregate data with its affiliates, joint marketers, agents and business partners. GrowthFountain may disclose aggregated user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes. You understand and agree that we may provide aggregate information to our partners about how Users interact with the Platform. You also understand that we share this type of statistical data with joint marketing partners to provide a metric for the effectiveness of specific marketing campaigns. We also may share data with affiliates and with vendors working on our behalf to protect our customers or to maintain the security of the Platform and our Services.
  • With Your Permission. As discussed above, GrowthFountain may disclose user data for a particular purpose. If you consent to additional uses of your User Data, we may share your information in other areas not listed above.

How We Protect Data

The security of your personal information is important to us. Your password and log-in credentials are a critical component of keeping your information safe and we expect you not to disclose your password to anyone. If you do share your password or personal information with others, you are responsible for all actions taken in the name of your account.

While we try to ensure that your information is secure on our system, no data transmission over the internet can be guaranteed to be 100% secure. Although we work hard to protect your privacy, User Data transmitted through the internet is likely to generate some risk that such data may be intercepted, hacked, hijacked or otherwise obtained without your consent or knowledge. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it.

What Information We Do Not Protect

We do not keep private any information provided to GrowthFountain that was intended to be shared publicly, including without limitation information made available through the internet or on the Platform in connection with any disclosure required by applicable law. For example, we do not keep private any messages posted on the communications channels, which are publicly available on the Platform. Additionally, we do not keep private any comments posted to any of the blogs or other content available publicly on the Platform. We also do not keep private any of the information contained in the Form C required by Regulation CF or any of the offering material filed publicly with any governmental or regulatory body.

Any ideas for new products or modifications to existing products, and other unsolicited submissions shall be deemed to be non-confidential and GrowthFountain shall be free to reproduce, use, disclose, distribute and exploit such information without limitation or attribution.

We do not keep private any social media posts that are made available publicly on the internet or any testimonials that we may post on the Platform, provided that you have given consent for such use. You agree that any such consent is irrevocable once obtained.

  • Voluntary Disclosure. By voluntarily providing us with User Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide User Data, you acknowledge and agree that such User Data may be transferred from your current location to the offices and servers of GrowthFountain and the authorized third parties referred to herein.

    You understand that you may opt not to disclose information provided that you discontinue your use of the Platform and Services. You acknowledge and agree that GrowthFountain has regulatory obligations that require the collection of certain information and that discontinuing your access to the Platform and Services is an appropriate and reasonable response should you ever opt to refrain from disclosing information that GrowthFountain determines is necessary for compliance with applicable law or for otherwise managing risk.

  • Social Media Features. You may have the ability to log in to our Platform using sign-in services such as Facebook Connect or LinkedIn. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. We may use or add other sign-in services in the future, and some of those services, like Facebook Connect, may give you the option to post information about your activities to share with others within your network. This Privacy Policy does not protect any publicly available social media posts.

    The Platform may also include social media features that may collect information about you (such as your IP address or which page you are visiting on our Platform). Some of these social media features, tools and widgets may be hosted by a third party and in such cases, your interactions with these social media features will be governed by the privacy policy of the company providing it.

  • Minors. Use of the Platform and the Services is limited to those persons who are over 18 years of age. GrowthFountain does not knowingly collect or solicit User Data from children under the age of 18 or knowingly allow children under the age of 18 to register. If you are under the age of 18, please do not use or submit any User Data through the Platform. We encourage parents and legal guardians to monitor their children's internet usage and to help enforce our Privacy Policy by instructing their children never to provide User Data on this Platform without their permission. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will take action to remove or delete that information as quickly as possible. If you have reason to believe that a child under the age of 18 has provided User Data to GrowthFountain through this Platform, please contact us immediately at @growthfountain.com so that we can investigate the matter.
  • Links to Other Web Sites. The Platform may contain links to other web sites not operated or controlled by GrowthFountain (collectively, "Third Party Sites"). The policies and procedures we describe here do not apply to Third Party Sites. The links from this Platform do not imply that GrowthFountain endorses or has reviewed any Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

    Once you have used links to leave the Platform, you understand that we cannot be responsible for the protection and privacy of any information which you provide whilst visiting sites not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

How Can You Obtain, Change or Modify Collected Data

You do not have the right to request access to the personal information that we record about you. Your rights are limited to receiving electronic copies of the documents that you have electronically signed.

To obtain access to these documents, you can visit your account settings for electronic download or you can email us for assistance at info@growthfountail.com. Any request should include your name, address, telephone number, and the recorded information to which you would like access. We may assess certain fees relating to any delivery charges that arise in responding to your request.

If your personal information changes, you may correct, update, or amend such information by making the change in your registered account settings page or by emailing our Customer Support at info@GrowthFountain.com.

You agree to the opt-out limitation described above and further agree that such limitation is supported by sufficient consideration in terms of your ability to access and use the Platform. To the extent that you wish to limit the collection of information, you will need to close your account and cease using the Platform and the Services.

How Long Do We Keep Your Data

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may be able to add or update certain information the we have collected. When you update information, however, we often maintain a copy of the unrevised information in our records. Please note that some information may remain in our records after deletion of your account.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our information practices. If we make any changes, we will change the last updated date at the top of this Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices. We will post changes to this Privacy Policy as well as annual reporting on our Privacy Policy on the Platform and other places we deem appropriate.

Contacting Us

We may send you service-related announcements when it is necessary or appropriate to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

If you have any comments or questions about GrowthFountain's Privacy Policy or the information practices of the Platform, please feel free to contact us at info@GrowthFountain.com or by mail at:

GrowthFountain LLC

79 Madison Avenue, 5th Floor

New York, NY 10016