DATED: August 2023
- The types of information we collect
- How we use information we collect
- How we share information we collect
- How we safeguard information we collect
- Other important privacy information
If you are a California resident, please also see the “Notice to California residents” section below
Please note that your relationship with Avid is also governed by our Platform Terms of Service and the transaction documents that you may enter into in connection with making an investment through our Platform. Avid also has relationships with third parties for purposes of cookies served on our Platform, as detailed below. You are encouraged to carefully review these sections as well.
Types of Information We Collect
To provide our Services, and facilitate exchanges between users of the Platform, we obtain personal information directly from you and obtain information about you indirectly through electronic communications and third parties (collectively, "Personal Data").
User Supplied Membership Information
Depending on the Services you seek to access we may require that you provide some or all of the following types of Personal Data :
If required to help us verify your identity, you may provide us a copy of your driver's license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet U.S. Bank Secrecy Act or anti-money laundering laws, US Treasury department rules or regulations or other legal requirements. If you seek to invest through an entity or corporation, you may provide us with documentation relating to the entity's jurisdiction of formation, legal status and ownership. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship.
In order to make an investment in securities offered through our Platform, you must provide us and our third party financial providers or partners with certain account and other payment information, such as information needed to make payment via ACH, wire, electronic checks, cryptocurrency, foreign currency or any other payment method accepted by us at such time. Our membership registration provides additional details on the types of payment information needed. For members who link or verify bank accounts over our Platform and/or one of these third-parties, you may further agree to your personal and financial information being transferred, stored, and processed by this third-party in accordance with their respective privacy policies.
Automatically or Passively Collected Information
In addition to information you directly provide, we automatically or passively collect information when you access or use our services, such as, but not limited to, your IP address, device identifiers, click path, use of our Platform and other electronic data. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Platform is being used, and for security and monitoring purposes. In order to determine whether your computer is supported by our system, we may collect additional technical information about your operating system and browser, as well as the presence of any software that our Platform may require to operate with your computer, or other third party software on your computer.
Additionally, we may collect, store and use "cookies". A "cookie" is a small amount of data, often including an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience to make it easier for you to use a website upon a future visit, as well as to help you navigate between pages efficiently. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies. However, cookies must be enabled on your web browser if you wish to access certain personalized features of our Services. We encourage you to carefully review this section in order to learn more, and explore your opt-out options for certain cookies that are not necessary to become a member on our Platform.
Types of cookies being used on our site:
- Session Cookies: These cookies are automatically erased whenever you exit the Platform. We use these cookies to grant users access to places on our Platform, and enable actions they must be logged on to do.
- Persistent Cookies: Persistent cookies usually have an expiration date in the future, and remain in your browser until they expire, or you manually disable them. Persistent cookies are used in order to track member usage patterns of our Platform, and understand what you do on our Platform.
TYPE OF COOKIES
WHO SERVES THE COOKIES
Strictly Necessary Cookies
Performance and Functionality Cookies
Adroll, Barometric, Bidswitch, Bing, Dianomi, Google Marketing Suite, Hubspot, Jeeng, Katz, Linkedin, Mountain, Outbrain, PandoraPippio, Quora, Taboola, Tapjoy, Twitter, Wisepops, Yahoo
Social Media Cookies
Facebook (Meta), Linkedin, Pinterest, TikTok, Twitter
How Do I Control Cookies
There are multiple ways to control how cookies are used on your Avid platform and your devices.
- Cookies within the Avid Platform. By using the Avid Platform, you consent to the use of types of cookies detailed herein.
- Advertising ID. You can customize your device settings to control advertising ID:
- On Apple devices: enable "Limit Ad Tracking" in your device settings.
- On Android devices: enable "Opt out of Ads Personalization" in device settings.
- Third Party Cookies Opt-Outs. Many of the third-party and social media cookies as listed above also prove opt-outs on their own websites. You can find details on their own policies, as listed above in our cookies used.
Please note that removing or rejecting all cookies could affect the functionality of the Platform and its services.
For more information about cookies, please visit www.allaboutcookies.org if you are located within the United States. If you are located within Europe, visit www.youronlinechoices.eu.
We may also use so-called "pixel tags" – small graphic images (also known as "web beacons" or "single-pixel GIFS") – to tell us what parts of our website have been visited, inform us of the reach and efficacy of our advertisements, or to measure the effectiveness of searches customers perform on our Site. Pixel tags also enable us to send email messages in a format customers can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users.
Some web browsers transmit "do-not-track" signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers.
We may send email messages that use a "click-through URL" linked to content on our Platform. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click text or graphic links in the email, or notify us at support@Avid.ooo.
We collect certain information about you when you visit the Platform and interact with any of our Services. We collect information about when you use Services, the pages within the Platform you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Platform, we retain information about your referral.
We collect information in connection with the transactions you become a party to through our Services, including your participation in primary offerings via the Platform and secondary purchase and sale transactions through the secondary market bulletin board. Transaction data includes, without limitation, the terms on which you purchase or sell securities and information relating to price, size, volume, class of securities, offers, acceptances, transfer restrictions, and any derivative data related thereto.
We collect information about you from third-party sources with which we maintain various commercial relationships. We utilize a third-party identity verification service provider to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services. We also receive information about you and your activities from third-party service providers, such as Google, LinkedIn, Meta, and other advertising, social media and market research partners who provide us with information about you, and/or your engagement with and interest in our Services. We may also receive information about you from our third-party marketing partners, under referral programs, IRA service providers, partnership agreements and/or under joint marketing arrangements.
How We Use Information We Collect
We may use your information for the following commercial purposes:
- To administer, operate, facilitate and manage your relationship with Avid and deliver the Services.
- To facilitate our business operations, including fulfilling our legal and regulatory requirements such as identity verification, validation, anti-money laundering and "Know Your Customer" protocols.
- To determine your eligibility to invest.
- To enable you to subscribe for securities, make and receive payments and execute transactions.
- To satisfy our record keeping and transfer agency obligations under applicable laws, rules and regulations.
- To communicate with you about the Services and target our marketing, advertising and sales efforts to enhance your user experience and increase engagement. These communications may alert you to new Services, offerings, features, content and promotional events.
- To provide you with information about our current Services, including onboarding materials, the availability and terms of new investment opportunities, reminders, information about your previous investments.
- To verify your identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies. We also use your information to debug, identify and correct errors;
- On a de-identified, aggregated basis, for research and development activities, including to analyze how you use the Services to help us understand usage patterns and know if there are problems with the Services or areas ripe for improvement;
- To contact you or, if applicable, your designated representative(s) by post, telephone, text message, electronic mail, facsimile, etc., in connection with your relationship with Avid, including with information and updates about our Services.
In addition, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of Avid' assets, or other corporate transaction affecting Avid, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract.
By using the Services, you consent to receiving calls and messages, including auto-dialed and pre-recorded message calls, and SMS messages (including text messages) from us, at any telephone numbers that you have provided or may provide in the future (including any cellular telephone numbers). Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You can "opt-out" of receiving these types of communications from us by following the directions provided elsewhere in this policy.
If your relationship with Avid ends, we will continue to treat your Personal Data, to the extent we retain it, as described in this policy.
How We Share Information We Collect
We do not buy, sell or share personal identifying information from, to or with third parties for their direct marketing or similar purposes without your consent. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or Services in exchange for your information.
The manner in which partners, service providers and others with whom we share and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your Personal Data into databases maintained to validate information for identity verification, including verification for anti-money laundering and "Know Your Customer" protocols.
The primary situations in which we share your data are as follows:
- Partnering Arrangements: We employ other companies to perform functions on our behalf, such as a broker dealer that underwrites and solicits investment in our offerings, service providers that assist in the administration of our Platform and our advertising and marketing efforts, identity verification services such as Onfido, data analytics companies that help us target our offerings, marketing partners such as Braze, Windfall and Hubspot, and payment providers such as Plaid, First Republic. We may need to share your information with these companies. These users may access this information so long as you are a member of the Platform.
- Service Providers: To operate the Services we share information about you as needed with our service providers, including financial institutions, broker-dealer(s), accountants, auditors, lawyers, payment processors, information technology consultants, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Platform and the Services. The information is only shared so long as you are a member or user of the Platform.
- Regulators: We may share information about you with US, state or international regulators, SEC, or FINRA where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas, including the requirements under the Federal Stored Communications Act ("SCA"), 18 U.S.C. Sections 2701-2712.
How We Safeguard Your Personal Data
Security Systems and Processes: We have put in place security systems designed to prevent unauthorized access to or disclosure of Personal Data, and we take all reasonable steps to secure and safeguard this Information, including:
- Our Platform's password-protected section requires users to give us unique identifiers such as their user ID and password and authenticate themselves prior to accessing the Services;
- We use industry standard encryption technology for any information we store;
- We provide access to our databases containing Personal Data on a need-to-know basis only; and
- We use automated tools to monitor network traffic to identify unauthorized attempts to upload information, change information, or otherwise seek to "hack into" our systems.
Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. However, please understand that this information should not be construed as a warranty that our security systems are fail proof. Due to the nature of internet communications and evolving technologies, we disclaim and cannot provide assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
Credit Card Security: Avid does not take or retain credit card information directly. Any credit card information submitted will be done through our third party financial providers and will be governed by their terms and conditions.
Other Important Privacy Information
Opting Out of Communications:
If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this policy, please follow the opt-out instructions, such as clicking "Unsubscribe" (or similar opt-out language), in those communications. You can also contact us at support@Avid.ooo to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Platform.
Changing or Deleting Information:
All users may review, update, correct or delete the user's Personal Data that Avid has on file by contacting us at support@Avid.ooo or, in certain cases, by accessing your member account. If you request, we will take reasonable steps to remove your name and other Personal Data from our databases. Please understand, however, that:
- it may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;
- if you request deletion of your information, you will be unable to use certain features of the Platform and any associated Services; and
- certain Personal Data may remain in our databases following the deletion of your account pursuant to our data retention policy.
We retain information we collect for as long as you use the Services (including your ownership of securities in Avid entities) or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.
Lost or Stolen Information:
You must promptly notify us if you become aware that any information provided by or submitted to the Platform is lost, stolen or used without permission.
Download or Access Your Personal Data on File:
You can ask us for a copy of your Personal Data, including a copy in machine readable form, by emailing us at support@Avid.ooo.
Children and Teens:
We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services. In the event we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at support@Avid.ooo
If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the FTC's website.
We Operate in the United States:
Avid is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.
European Economic Area Residents
If you are an individual residing in the European Economic Area ("EEA"), we collect and process information about you only where we have legal bases for doing so under applicable EU laws, including the European General Data Protection Regulation ("GDPR"). The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, perform a contract with you, take necessary steps prior to performing a contract or at your request, provide customer support, and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services, to personalize services you receive, and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or we need to process your data to comply with a legal requirement. If you have consented to our use of information about you for a specific purpose, you may change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you may object to that use though, in some cases, this may mean no longer using the Services. To do so, please email us at support@Avid.ooo.
In the event of a data breach, we will endeavor to notify you within seventy-two (72) hours of detection of a breach that we conclude poses significant risks to your rights and freedoms under the GDPR. You may also lodge a complaint with a supervisor authority in the EEA member state in which you reside.
Pursuant to the California Consumer Privacy Act ("CCPA"), residents of California have certain rights concerning a business with which the California resident has an established business relationship regarding the Personal Data the business collects, uses and discloses.
California residents have the right to know what Personal Data a business has about them. California residents can obtain a report of this Personal Data once every twelve (12) months.
When California residents terminate their accounts on the Platform, they have the right to have their information forgotten, except to the extent the Platform is prohibited by law from deleting the information.
California residents also have the right to opt out from their data being sold or otherwise monetized with third parties through a ""Do Not Sell" request.
To request your Personal Data information, exercise your Right to Request Deletion, or exercise your Do Not Sell request, please contact us by email at support@Avid.ooo.
If you have any questions about this policy, the practices of this Platform, or your dealings with this Platform, please contact us by e-mail as follows: support@Avid.ooo
Effective Date: August 1st, 2023